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FREY v. COMPTROLLER

No. 62, September Term, 2009.

29 A.3d 475 (2011)

422 Md. 111

Timothy A. FREY, et al. v. COMPTROLLER OF the TREASURY.

Court of Appeals of Maryland.

September 29, 2011.

Attorney(s) appearing for the Case

Harry D. Shapiro (Seth J. Groman of Saul Ewing LLP, Baltimore, MD), on brief, for petitioners/cross-respondents.

John K. Barry, Asst. Atty. Gen. (Douglas F. Gansler, Atty. Gen. of Maryland, Baltimore, MD), on brief, for respondent/cross-petitioner.

Argued before BELL, C.J., HARRELL, BATTAGLIA, GREENE, MURPHY, ADKINS and BARBERA, JJ.

BARBERA, J.

In this case we consider the State's authority to impose a certain tax known as the "Special Nonresident Tax" ("SNRT") upon nonresidents who neither live nor work in Maryland but have a source of income in the State. Petitioners David S. and Judith W. Antzis, Timothy A. and Mary S. Frey, and Rudolph Garcia and Randi E. Pastor-Garcia reside in Pennsylvania but pay Maryland State income taxes on the income earned by each husband as a partner in Saul Ewing...

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