Comptroller of the Treasury v. Hickey

CATHELL, Judge.

At issue in this case is the application of section 10-703(c)(l) of the Tax-General Article. With certain exceptions, section 10-703(a) provides taxpayers with a credit against Maryland income tax “for tax on income paid to another state.” The amount of this credit is determined under section 10 — 703(c)(1). This section provides:

[T]he credit allowed a resident under subsection (a) of this section is the lesser of:(i) the amount of allowable tax on income that the resident paid to another state; or(ii) an amount that does not reduce the State income tax to an amount less than…