Comptroller v. Fc-Gen Operations Inv.

Summary

The Supreme Court of Maryland held that, when deference is appropriate in reviewing a Tax Court decision concerning the interpretation of tax laws, deference is owed to the Comptroller rather than the Tax Court. It further held that a pass-through entity that made estimated tax payments and later incurred a taxable loss with no tax liability is a claimant entitled to a refund under the plain language of the refund statute. The court affirmed the judgment awarding FC-GEN a refund and declined to decide the remaining issues concerning deposits, payments, and the voluntary-payment rule.