Comptroller of Treasury v. Gannett Co.

CATHELL, Judge.

The Comptroller of the Treasury, appellant, appeals a ruling from the Circuit Court for Montgomery County that appellant lacked the authority to assess additional income tax against Gannett Company, Inc., appellee, by imputing interest income from certain intercompany debt not reported on appellee’s federal income tax returns. We agree with the circuit court and, accordingly, affirm the lower court.

I. Background

Appellee is a Delaware corporation, headquartered in Virginia, with computer support facilities in Silver Spring, Maryland. A leading corporation in the media industry,…