King v. Comptroller of the Treasury

We are called upon to interpret Section 13-1104(c)(2)(i) of the Tax-General Article of the Maryland Code, 1 regarding the statute of limitations within which a taxpayer must file a Maryland tax refund claim after a federal audit of a partnership of which she was a limited partner. The question presented by the Petitioner, Wanda T. King, is as follows:

Did the Maryland General Assembly, in enacting TG 13-1104(c)(2)(i), intend for the statute of limitations to begin to run on Maryland refund claims on the date of a taxpayer’s federal income tax liability is no longer subject to administrative…