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INSURANCE COMM'R v. BANKERS

No. 128, September Term, 1991.

326 Md. 617 (1992)

606 A.2d 1072

INSURANCE COMMISSIONER OF THE STATE OF MARYLAND, v. BANKERS INDEPENDENT INSURANCE COMPANY.

Court of Appeals of Maryland.

June 5, 1992.

Attorney(s) appearing for the Case

Randi F. Reichel, Asst. Atty. Gen. (J. Joseph Curran, Jr., Atty. Gen., both on brief), Baltimore, for appellant.

Lloyd David Yavener, Gaithersburg, for appellee.

Argued before MURPHY, C.J., ELDRIDGE, RODOWSKY, CHASANOW, KARWACKI, and ROBERT M. BELL, JJ., and CHARLES E. ORTH, Jr., Judge of the Court of Appeals (retired), Specially Assigned.

MURPHY, Chief Judge.

This case involves the collection of taxes from a Maryland domestic insurance company on gross direct premiums received for coverage provided for risks located beyond the territorial limits of the United States.

I.

Maryland Code (1991) Art. 48A, § 632 provides in pertinent part:

"(a) Gross direct premiums. — (1) There is imposed upon every insurance company a tax on all new and renewal gross direct...

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