K.S.A. 1979 Supp. 74-2426 has heretofore been narrowly construed by this court. In City of Kansas City v. Jones Laughlin Steel Corp., 187 Kan. 701, 704, 360 P.2d 29 (1961), we held that "the first sentence of section 74-2426 . . . limits the applicability of the statute to such cases as are appealed from the directors [of revenue and property valuation] to the board of tax appeals, as distinguished from original applications. It is readily apparent that the section is inapplicable to original applications for relief from tax grievances had before the board of tax appeals under G.S. 1949, 79-1702." We noted that relief could be sought in an original action for injunction, mandamus or quo warranto, but not by way of appeal. The Jones Laughlin rule was followed in Union Pacific Railroad Co. v. Sloan, 188 Kan. 231, 361 P.2d 889 (1961).

In In re Lakeview Gardens, Inc., 227 Kan. 161, 166, 605 P.2d 576 (1980), this court determined that K.S.A. 1979 Supp. 74-2426, governing appeals from the BOTA, did not authorize appeals to the courts from a tax grievance proceeding filed before the BOTA pursuant to K.S.A. 79-1702. See also City of Kansas City v. Jones Laughlin Steel Corp., 187 Kan. 701, 704, 360 P.2d 29 (1961); Union Pacific Railroad Co. v. Sloan, 188 Kan. 231, 233, 361 P.2d 889 (1961); Board of Johnson County Comm'rs v. Ameq, Inc., 227 Kan. 93, 94, 605 P.2d 119 (1980). It was further held that K.S.A. 1979 Supp. 60-2101( d), the omnibus statute authorizing appeals from decisions of administrative agencies, did not authorize appeals from an order of the BOTA and did not enlarge the limited right of appeal provided by K.S.A. 74-2426 (Weeks).

It may be limited by the legislature to any class or classes of cases. or in any manner, or it may be withdrawn completely. It lies within the legislative domain to determine from what orders or judgments an appeal may be taken. ( In re Waterman, 212 Kan. 826, 830, 512 P.2d 466; State v. Burnett, 222 Kan. 162, 166, 563 P.2d 451.) Courts have no inherent appellate jurisdiction over the official acts of administrative officials or boards except where the legislature has made some statutory provision for judicial review. ( In re Chicago, R.I. P. Rly. Co., 140 Kan. 465, 467, 37 P.2d 7; City of Kansas City v. Jones Laughlin Steel Corp., 187 Kan. 701, 703, 360 P.2d 29.) . . ." (p. 467) Every appeal from a decision of the KCCR is governed and limited by the provisions of K.S.A. 44-1011 and if an appeal from a "no probable cause" finding is not authorized under that section then no appeal is possible.

In the absence of statutory provisions therefor, district courts are without jurisdiction to entertain appeals from nonjudicial acts of administrative officials or boards. ( City of Kansas City v. Jones Laughlin Steel Corp., 187 Kan. 701, 360 P.2d 29.) 2.

Hence no appeal is available, but the Board's action is challengeable by an appropriate extraordinary remedy such as injunction, mandamus or quo warranto. City of Kansas City v. Joness&sLaughlin Steel Corp., 187 Kan. 701, Syl. P 2, 360 P.2d 29 (1961); Brinson, 223 Kan. 465, Syl.

The motive of the Board has not been challenged and we find no showing that the Board's actions in implementing the Plan were "illegal", "fraudulent", or "oppressive official conduct". City of Kansas City v. Jones and Laughlin Steel Corp., et al., 187 Kan. 701, 360 P.2d 29 (1961) and Board of County Commissioners v. Brookover, et al., 198 Kan. 70, 422 P.2d 906 (1967). The allegation that the Board exceeded its statutory authority by negotiating with HEW for continued receipt of federal education funds in return for District 259's agreement to operate its schools in accordance with the Plan cannot be sustained either in fact or law.

These types of proper actions were described earlier in the court's opinion: "In City of Kansas City v. Jones Laughlin Steel Corp., 187 Kan. 701, 360 P.2d 29, while holding that no appeal would lie from the particular order of the board of tax appeals there challenged, we observed: `However, the courts are always open to hear meritorious complaints against illegal or oppressive acts of non-judicial public boards and officials, either at the instance of the state or of a private citizen especially aggrieved thereby; but not by appeal where no statute confers a right of appeal.

In the case of In re Lakeview Gardens, Inc., 227 Kan. 161, 605 P.2d 576 (1980), it was held that the tax grievance statutes, Article 17 of Chapter 79 of the Kansas Statutes Annotated, contained no provision for a right of appeal to the courts from orders of BOTA correcting or refusing to correct irregularities. The court held specifically that K.S.A. 1979 Supp. 74-2426, governing appeals from orders of BOTA was inapplicable to original applications for relief from tax grievances before BOTA under K.S.A. 79-1702. That case followed a prior decision, City of Kansas City v. Jones Laughlin Steel Corp., 187 Kan. 701, 704, 360 P.2d 29 (1961), which limited appeals to the courts under 74-2426 to such cases as are appealed from the directors of revenue and property valuation as distinguished from original applications. It held that, there being no statutory provision for appellate review, relief could be found in such equitable remedies as quo warranto, mandamus, or injunction. "In the 1980 legislative session, the House Committee on Assessment and Taxation considered the confusion in the procedural aspects of the Kansas taxing laws. It introduced comprehensive legislation which sought to achieve a number of specific objectives: (1) The elimination of direct actions filed in the district court in tax grievance cases and the requirement in all tax protest cases of a hearing before the board of tax appeals, with right of appeal to the district court; (2) a codification of the tax exemption procedure in Chapter 79, Article 2, with provision for judicial review of tax exemption matters under an omnibus appeals procedure stat

( In re Chicago, R.I. P. Rly Co., [ 140 Kan. 465, 468, 37 P.2d 7]; State, ex rel. v. Davis, 144 Kan. 708, 710, 62 P.2d 893.)'" (Emphasis added.) State, ex rel. v. Unified School District, 218 Kan. at 50 (quoting City of Kansas City v. Jones Laughlin Steel Corp., 187 Kan. 701, 703, 360 P.2d 29 [1961]). There is a vast difference between "illegal, arbitrary, and unreasonable" and "illegal, fraudulent, or oppressive."

In the case of In re Lakeview Gardens, Inc., 227 Kan. 161, 605 P.2d 576 (1980), it was held that the tax grievance statutes, Article 17 of Chapter 79 of the Kansas Statutes Annotated, contained no provision for a right of appeal to the courts from orders of BOTA correcting or refusing to correct irregularities. The court held specifically that K.S.A. 1979 Supp. 74-2426, governing appeals from orders of BOTA was inapplicable to original applications for relief from tax grievances before BOTA under K.S.A. 79-1702. That case followed a prior decision, City of Kansas City v. Jones Laughlin Steel Corp., 187 Kan. 701, 704, 360 P.2d 29 (1961), which limited appeals to the courts under 74-2426 to such cases as are appealed from the directors of revenue and property valuation as distinguished from original applications. It held that, there being no statutory provision for appellate review, relief could be found in such equitable remedies as quo warranto, mandamus, or injunction. In the 1980 legislative session, the House Committee on Assessment and Taxation considered the confusion in the procedural aspects of the Kansas taxing laws. It introduced comprehensive legislation which sought to achieve a number of specific objectives: (1) The elimination of direct actions filed in the district court in tax grievance cases and the requirement in all tax protest cases of a hearing before the board of tax appeals, with right of appeal to the district court; (2) a codification of the tax exemption procedure in Chapter 79, Article 2, with provision for judicial review of tax exemption matters under an omnibus appeals procedure statut