ANNAPOLIS -- The far-ranging plan designed to raise taxes in Maryland but make them more equitable hit a solid wall of opposition when the tax-wary General Assembly convened its 1991 session last week.

But the proposal, produced after a three-year study by a commission headed by Montgomery County lawyer R. Robert Linowes, appears to be gaining converts in some unlikely places.

After meeting Friday with Gov. William Donald Schaefer, the county executives of Montgomery and Prince George's counties had kind words for some parts of the commission's plan, which overall would raise $800 million annually.

By making the income tax more progressive and expanding the sales tax, the commission's recommendation would take large chunks of the money from the relatively wealthy Washington suburbs. But 64 percent of the new local aid would be redistributed to Baltimore and poorer rural counties, which caused suburban political leaders to recoil when the plan was unveiled last month.

However, Montgomery County Executive Neal Potter said in an interview that trimming hundreds of millions of dollars to balance the state budget this year seems unnecessary when the Linowes Commission suggested "so many revenue sources to be tapped."

For his part, Prince George's County Executive Parris N. Glendening said parts of the Linowes plan make sense.

"It's clear to me there is a consensus among local elected officials on what must be done to fund education and how to do it," Glendening said. He added that he and other county leaders expect to begin an organized effort within two weeks to help sell some undisclosed portion of the Linowes plan.

Their attitudes, coming as the two counties also are slicing local budgets to live within reduced revenue, contrast starkly with those of many legislators from Montgomery and Prince George's, who are among the most ardent opponents of raising taxes and channeling a large share of the proceeds to Baltimore.

Sen. Laurence Levitan (D-Montgomery), chairman of the influential Senate Budget and Taxation Committee, said Friday that an analysis still underway appears to raise strong questions about whether less-wealthy taxpayers would benefit from the Linowes recommendations.

Linowes, who has embarked on a missionary effort to promote the proposal, said yesterday that he doesn't find the positions of Potter and Glendening remarkable. From a political viewpoint, he said, local leaders see as acceptable a proposal that he maintains generally would increase taxes for Maryland residents earning more than $40,000 a year.

"The majority of their constituents will not be adversely affected but would benefit . . . . " he said.

Potter, a student of local government finance, said the Linowes report "talks about things that are politically reasonable," but he acknowledged that such a sentiment would not be wildly popular in Montgomery County.

"Some of our wealthy taxpayers would obviously pay a lot more," Potter said. "I'll talk to our budget people and see what's possible, what's fair."

Schaefer, in a meeting with county leaders Friday, did not urge them to support the Linowes recommendations, several participants said. But by outlining cuts in the state budget and local aid programs, the governor continued his behind-the-scenes strategy of building pressure on the legislature.

Linowes appears willing to take support where he can get it.

"If the legislators are aware that the local leaders who are closest to the voters are interested in trying to support the program, they're going to have to be aware there's some movement there to cause interest and a careful look at what's been suggested," he said.