Dun & Bradstreet Corp. v. Comptroller of the Treasury

ALPERT, Judge.

We are asked to decide whether a notice of assessment intended for a subsidiary corporation was legally sufficient when the Comptroller mailed the notice in the parent corporation’s name to the parent corporation’s address to the attention of the parent’s employee who handled the subsidiary’s tax audit from which the assessment arose.

FACTS

Dun & Bradstreet, Inc. (D & B, Inc.) is a wholly owned subsidiary of Dun & Bradstreet Corp. (D & B Corp.). For the calendar years 1981, 1982, and 1983, the Comptroller of the Treasury (the Comptroller) audited the Maryland corporation income…