Legal Opinion

Gore Enterprise Holdings, Inc. v. Comptroller of the Treasury

Court of Appeals of Maryland

Decided March 24, 2014No. 36/13PublishedCited by 28 opinions

1Opinion of the CourtAdkins, J.

Benjamin Franklin once wrote that “nothing can be said to be certain, except death and taxes.” 1 But Mr. Franklin did not promise certainty about what could be taxed or by whom. This case allows us to bring such certainty to a particular creature in the modern corporate landscape. To that end, we examine the Comptroller of Maryland’s (“Comptroller”) authority to tax the income of two out-of-state subsidiary corporations based on the subsidiaries’ relationship with their Maryland parent, the subsidiaries’ substance as corporations, and all the entities’ activity in Maryland.

FACTS AND LEGAL…

2Cases cited47 opinions

  1. Bivens v. Six Unknown Named Agents of Federal Bureau of NarcoticsSupreme Court of the United States · 1971
  2. Walden v. FioreSupreme Court of the United States · 2014
  3. College Savings Bank v. Florida Prepaid Postsecondary Education Expense BoardSupreme Court of the United States · 1999
  4. Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
  5. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943

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3Cited by28 opinions

  1. Comptroller v. FC-GEN Operations Inv.Court of Appeals of Maryland · 2022
  2. Allmond v. Department of Health & Mental HygieneCourt of Appeals of Maryland · 2016
  3. Emergency Remedy of Bd. of ElectionsCourt of Appeals of Maryland · 2023
  4. Medical Management & Rehabilitation Services, Inc. v. Maryland Department of Health & Health HygieneCourt of Special Appeals of Maryland · 2015
  5. NIHC, Inc. v. Comptroller of the TreasuryCourt of Appeals of Maryland · 2014

23 more not listed; retrieve them via the Exa API.

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