Register of Wills for Baltimore County v. Arrowsmith
Court of Appeals of Maryland
1Opinion of the Court
BATTAGLIA, Judge.
We issued a writ of certiorari in this case to determine whether Maryland’s statute of limitations with respect to filing a claim for refund of inheritance taxes was rendered inapplicable by the Treaty ratified pursuant to the Convention Between the United States of America and the Federal Republic of Germany for the Avoidance of Double Taxation with Respect to Taxes on Estates, Inheritance, and Gifts. 1
I. BACKGROUND
A. Facts
This controversy arose in connection with the estate of Harold Arrowsmith (hereinafter “decedent”), who died intestate in Germany on August 15, 1989. The…
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