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HULL v. COMPTROLLER

No. 122, September Term, 1987.

312 Md. 77 (1988)

537 A.2d 1188

WILLIAM HULL ET AL. v. COMPTROLLER OF THE TREASURY, INCOME TAX DIVISION.

Court of Appeals of Maryland.

March 8, 1988.

Attorney(s) appearing for the Case

Charles C. Shelton (T. Scott Basik and Semmes, Bowen & Semmes, all on brief), Baltimore, for appellants.

John K. Barry, Asst. Atty. Gen. (J. Joseph Curran, Jr., Atty. Gen., and Gerald Langbaum, Asst. Atty. Gen., all on brief), Annapolis, for appellee.

Argued before ELDRIDGE, COLE, RODOWSKY, McAULIFFE, ADKINS and BLACKWELL, JJ., and CHARLES E. ORTH, Jr., Associate Judge of the Court of Appeals of Maryland (retired), Specially Assigned.

CHARLES E. ORTH, Jr., Judge (retired), Specially Assigned.

This case is about the assessment of income taxes by the Comptroller of the State of Maryland against two nonresident former Maryland bay pilots.

Pilots are covered by Article 74 of the Maryland Code (1957, 1983 Repl.Vol.).1 Section 10 provides:

Every foreign vessel and every American vessel engaged in foreign trade, including such vessels towing or being towed...

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