Kushell v. Department of Natural Resources

In this case we consider whether Maryland tax liability under § 8-716(c)(l)(iv) of the State Boat Act for “[t]he possession within the State of a vessel purchased outside the State to be used principally in the State” requires that the out-of-state purchase have been made with an intent to use the vessel principally in Maryland. We find that the plain language of the statute requires this result. Both parties to this appeal agree that appellant Charles Kushell did not intend, at the time of purchase, to principally use his vessel in Maryland. We shall reverse the Circuit Court’s order…