Legal Opinion

Comptroller v. FC-GEN Operations Inv.

Court of Appeals of Maryland

Decided December 19, 2022No. 7/22Published

1Opinion of the Court

Comptroller of Maryland v. FC-GEN Operations Investments LLC, No. 7, September Term, 2022, Opinion by Booth, J. ADMINISTRATIVE LAW & PROCEDURE — JUDICIAL REVIEW — AGENCY DEFERENCE ON MATTERS RELATED TO INTERPRETATION OF TAX LAWS. In connection with judicial review of a Tax Court decision in which a party alleges an error of law, where the reviewing court determines that it is appropriate to give a degree of deference to an agency’s interpretation of tax laws, the agency to whom deference is owed is the Comptroller, as the agency responsible for administering the tax laws and promulgating…

2Cases cited42 opinions

  1. Skidmore v. Swift & Co.Supreme Court of the United States · 1944
  2. Auer v. RobbinsSupreme Court of the United States · 1997
  3. Lockshin v. SemskerCourt of Appeals of Maryland · 2010
  4. Board of Physician Quality Assurance v. BanksCourt of Appeals of Maryland · 1999
  5. Ramsay, Scarlett & Co. v. Comptroller of TreasuryCourt of Appeals of Maryland · 1985

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