At&T Communications of Maryland, Inc. v. Comptroller of the Treasury

AT&T Communications of Maryland, Inc., appeals the decision of the Circuit Court for Baltimore City that affirmed a decision of the Maryland Tax Court. The tax court, in turn, had affirmed a decision of the Comptroller of the Treasury, appellee, to assess AT&T $5,160,899.45, plus interest, for unpaid sales tax based upon sales of “900 telecommunication services.” The tax court held that AT&T is liable for the tax because AT&T failed to collect the tax from the consumers and remit it to the State. 1 We hold that AT&T is liable for the sales tax because AT&T was (a) not merely a “common…