ALPERT, Judge.
For the first time, in a corporate income tax case, we are asked to decide which party bears the burden of establishing the tolling of the statute of limitations.
This is an appeal by the Comptroller of the Treasury, Income Tax Division, from a judgment of the Circuit Court for Baltimore City affirming a decision of the Maryland Tax Court. The tax court reversed an assessment for Maryland corporate income tax, originally entered on April 16...
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