Comptroller v. Fc-Gen Operations Inv.

Summary

The Court held that, when deference is appropriate in reviewing a Tax Court decision involving interpretation of tax laws, any deference is owed to the Comptroller, which administers the tax laws, rather than to the Tax Court. It further held that a pass-through entity that made estimated tax payments but later incurred a taxable loss and had no tax liability is entitled to a refund under the plain language of the refund statute. The Court affirmed the judgment ordering the refund and did not reach the remaining questions concerning the characterization of the payments or the voluntary-payment rule.