Zorzit v. Comptroller of Md.

John Zorzit and Nick’s Amusements (collectively, “Nick’s”) were ordered to pay $5,770,353.18 by the Maryland Tax Court—$2,159,724.97 in unpaid admissions and amusement taxes, interest on those taxes, and a fraud penalty of $1,079,862.45. Nick’s does not dispute failing to pay taxes, but contests the amount owed and disagrees with the fraud penalty. It argues that the Comptroller’s assessment that was the basis for the Tax Court’s Order was fatally flawed and that the Comptroller failed to prove the necessary intent to defraud. We disagree with both arguments and affirm.

I. BACKGROUND

From 1993…