Rossville Vending Machine Corp. v. Comptroller of Treasury

EYLER, Judge.

This case of first impression requires us to determine the period of limitations applicable to enforcement of a recorded tax lien.

On September 25, 1985, the Comptroller of the Treasury, appellee (Comptroller), levied an assessment against Rossville Vending Machine Corporation, appellant (taxpayer), for unpaid admission and amusement taxes in the amount of $859,-560.581 for the period of December 15, 1982 through March 6, 1985. On September 27, 1985, the Comptroller filed a notice of tax lien in the Circuit Court for Baltimore County for the amount of the assessment. On September…