Mr. Pizza II, Inc. v. Comptroller of the Treasury

WILLIAM W. WENNER, Judge, Retired, specially assigned.

The genesis of this appeal is a judgment entered by the Circuit Court for Anne Arundel County affirming a decision of the Maryland Tax Court. Appellant, Mr. Pizza II, Inc. (“Mr. Pizza”), contends that because appellee, the Comptroller of the Treasury (the Comptroller), did not mail a notice of assessment within six months after receiving notice of a bulk sales transfer, the six-month limitations, period set forth in § 6-111 of the Commercial Law Article bars the Comptroller from imposing personal liability on Mr. Pizza. The Comptroller…