Comptroller of the Treasury v. Clyde's of Chevy Chase, Inc.

I agree with the Court that “this decision is limited to its unique facts.” In particular, I am convinced that when the decision we review is that of the Maryland Tax Court, an administrative agency, “the [Tax Court’s] decision is viewed in *514a light most favorable to the agency, since decisions of administrative agencies are prima facie correct.” Supervisor of Assessments v. Keeler, 362 Md. 198, 209, 764 A.2d 821, 827 (2001) (citations omitted); see also Comptroller v. Digi-Data Corp., 317 Md. 212, 231, 562 A.2d 1259, 1269 (1989). Indeed, “[e]ven with regard to some legal issues, a degree of…