Comptroller of the Treasury v. Zorzit

In this appeal, we consider whether the Comptroller’s Notice of Lien for Unpaid Taxes was properly challenged and vacated in the circuit court during pendency of the taxpayer’s appeal in the Maryland Tax Court. Appellee John Zorzit (“Zorzit”) — the taxpayer in this case — was the president of Nick’s Amusements, Inc. (“Nick’s”), a company charged in federal court with money laundering and operating an illegal gambling operation. Appellant, Comptroller of Maryland, assessed deficiency taxes and penalties against Zorzit and Nick’s for under-reported gross income in Nick’s’ tax returns.

Zorzit and…