Stewart Title Guaranty Co. v. State Tax Assessor

[¶ 1] The State Tax Assessor appeals from a judgment of the Superior Court (Kennebec County, Studstrup, J.) vacating the tax assessment against Stewart Title Guaranty Company for the years 1999, 2000, 2001, and 2002, and granting and denying, in part, both parties’ motions for summary judgment. The court ultimately remanded the matter to the State Tax Assessor for a determination of the appropriate tax pursuant to 36 M.R.S. § 2519 (2005). The State Tax Assessor contends that the court incorrectly interpreted “gross direct premiums” as provided in 36 M.R.S. § 2513 (2005). Stewart argues that…