NCR Corp. v. Comptroller of the Treasury

ADKINS, Judge.

This case involves corporate tax assessments by the Comptroller of the Treasury (Comptroller) against NCR Corporation (NCR) for the tax years 1972 through 1977. NCR contends that:

1. It should have been allowed to deduct gross-up from its federal taxable income for 1976;

2. it should have been allowed to deduct domestic placement interest income from its federal taxable income; and

3. the Comptroller incorrectly applied the Maryland apportionment formula to NCR’s foreign-source income when he excluded from the denominators the foreign subsidiaries’ property, payroll, and sales that…