Matthew Bender & Co. v. Comptroller of Treasury

ALPERT, Judge.

The Maryland Tax Court ordered a refund of income taxes and interest for the calendar years 1975 through 1980, inclusive, to be paid by the Comptroller of the Treasury (appellee) to Matthew Bender and Company, Incorporated (appellant). The Circuit Court for Baltimore City reversed that decision. This appeal followed.

PROCEDURAL BACKGROUND

On or about September 3, 1981, an auditor in the Comptroller’s Corporation Section mailed a notice to Bender, advising that it was liable for Maryland income taxes for the years 1975 through 1980. That notice was based on the auditor’s evaluation…