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NCR CORP. v. COMPTROLLER

No. 87, September Term, 1987.

313 Md. 118 (1988)

544 A.2d 764

NCR CORPORATION v. COMPTROLLER OF THE TREASURY, INCOME TAX DIVISION.

Court of Appeals of Maryland.

Decided July 29, 1988.

Motion for Reconsideration Denied August 25, 1988.

Attorney(s) appearing for the Case

Roger D. Redden, E. Stephen Derby, Kurt J. Fischer and Piper & Marbury, Baltimore, and William L. Goldman (argued), James A. Riedy and Lee, Toomey & Kent, Washington, D.C., on the brief, for appellant.

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

Shapiro and Venable, Baetjer & Howard, Baltimore, on the brief, for amicus curiae The Committee on State Taxation of the Council of State Chambers of Commerce.

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.

ADKINS, Judge.

This case involves corporate tax assessments by the Comptroller of the Treasury (Comptroller) against NCR Corporation (NCR) for the tax years 1972 through 1977. NCR contends that:

1. It should have been allowed to deduct gross-up from its federal taxable income for 1976; 2. it should have been allowed to deduct domestic placement interest income from its federal taxable income; and 3. the Comptroller incorrectly applied...

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