Pan American Sulphur Co. v. State Department of Assessments & Taxation

I dissent because in my opinion Ordinance No. 1340 of the Mayor and City Council of Baltimore, approved April 7, 1958 (Ordinance 1340) provides in clear and unambiguous language for the exemption from personal property taxation of the liquid sulphur storage facility in question which is “used entirely or chiefly in connection with manufacturing in Baltimore City.” The same facility in my opinion is also exempt from State taxation by the clear and unambiguous provision of Code (1965 Repl. Vol.) Article 81, § 9 (23) as being “used in manufacturing.” Pan Am, as I see it, is entitled to the tax…