Frey v. Comptroller of the Treasury
Court of Appeals of Maryland
1Opinion of the CourtBarbera, J.
In this case we consider the State’s authority to impose a certain tax known as the “Special Nonresident Tax” (“SNRT”) upon nonresidents who neither live nor work in Maryland but have a source of income in the State. Petitioners David S. and Judith W. Antzis, Timothy A. and Mary S. Frey, and Rudolph Garcia and Randi E. Pastor-Garcia reside in Pennsylvania but pay Maryland State income taxes on the income earned by each husband as a partner in Saul Ewing, LLP (“the firm”), a multi-state law firm with offices in Maryland, Pennsylvania, Delaware, Washington, D.C., New York, and New Jersey. In…
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