The Linowes Commission has made far-reaching proposals for change in the Maryland tax structure. The editorial of Dec. 6 asks whether this is a good time to "load on every change proposed" and answers in the negative. One proposal that definitely should not be adopted either now or in the future is the proposed 2 percent personal property tax on cars and boats.

I can think of no tax-policy professionals who favor personal property taxes. The taxes are narrowly based, inherently discriminatory and can be administrative nightmares. Most states, in fact, have been moving away from personal property taxes, at least where they cause economic dislocation and where fair market value cannot be readily determined. The "user fee" approach in the commission proposal -- dedicating one half of the automobile tax to the Transportation Trust Fund and the boat tax to the cost of the Chesapeake Bay clean-up -- has a superficial attraction but is also flawed. Some problems with the tax:

Regressive Impact. In many cases the impact of a 2 percent personal property tax would be retroactive and highly regressive. A family of modest means, who has sacrificed to buy a new or nearly new car for necessary transportation, would find itself hit with an unexpected annual tax burden large in relation to its income.

Economic Dislocation. Sales and employment in the state's auto and marine industries, already weakened by recession, would be continually penalized. In fact, an annual assessment would be a much more daunting obstacle to the prospective car or boat buyer than an initial sales/use tax of a much higher rate. The personal property tax approach will encourage continued use of less fuel efficient, polluting old clunkers, which would be assessed at low values.

Market Value Not Recognized. Particularly in the marine field, where there is no recognized "blue book" of market values, any arbitrary measure is very unlikely to reflect the extremely depressed market conditions of recent years.

User Benefit Not Sufficiently Related. Auto and boat owners already pay significant "user charges," particularly through fuel taxes, which at least have a reasonable relationship to use of facilities.

It is true that our neighbor state of Virginia imposes a similar personal property tax, but Virginia's tax structure, outside of this tax, is significantly less burdensome than Maryland's. Virginia counties, which have a local option as to the tax rate, have found the tax on boats so onerous and disruptive that a number of them have had to slash the rate substantially.

Personal property taxes certainly do not belong in any broad based and equitable tax system. It is hard to fathom why a reform-minded commission would recommend such an undesirable approach, other than the fact that a registration number conveys an opportunity to tax. EDWARD A. SPRAGUE Gaithersburg