ALPERT, Judge.
The Maryland Tax Court ordered a refund of income taxes and interest for the calendar years 1975 through 1980, inclusive, to be paid by the Comptroller of the Treasury (appellee) to Matthew Bender and Company, Incorporated (appellant). The Circuit Court for Baltimore City reversed that decision. This appeal followed.
PROCEDURAL BACKGROUND
On or about September 3, 1981, an auditor in the Comptroller's Corporation Section mailed a notice...
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