Department of Transportation v. White Oak Corporation

Summary

The court held that the Comptroller properly reduced White Oak's judgment payment by the amount of taxes White Oak owed because the governing statute required that reduction when the taxes were not subject to a timely administrative appeal. The court also rejected White Oak's collateral estoppel argument, reasoning that applying preclusion mechanically would undermine the statutory tax-collection scheme and allow White Oak to avoid taxes it could have challenged administratively.