MARYLAND, COMPTROLLER OF MARYLAND v. Ciotti

OPINION

J. FREDERICK MOTZ, District Judge.

This is an appeal from an order entered by the Bankruptcy Court to start discharging tax debts owed by Denise Ciotti to the State of Maryland for the years 1992 through 1996. The order of the Bankruptcy Court will be reversed. 1

The material facts are not in dispute. In 1996 Ciotti filed Maryland income tax returns for the years 1992, 1993, 1994, 1995, and 1996. In 1998 the Internal Revenue Service issued a Letter of Determination making adjustments to Ciotti’s income tax returns that substantially increased her federal adjusted income for each of those…