IN THE MATTER OF THE COMPTROLLER OF MD.

No. 81, Sept. Term, 2023.

328 A.3d 811 (2024)

264 Md. App. 23

In the MATTER OF the COMPTROLLER OF MARYLAND.

Appellate Court of Maryland.

Reconsideration Denied February 3, 2025.


Attorney(s) appearing for the Case

Argued by Michael B. Kimberly, McDermott Will & Emery LLP, Washington, DC (Alexander T. Mitchel, Mitchel Law, PLLC, Washington, DC; Doug Sigel, Ryan Law Firm, LLP, Austin TX, on brief), for Appellant.

Argued by Michael W. Fox, Asst. Atty. Gen. (Anthony G. Brown, Atty. Gen. of Maryland, Baltimore, MD), on brief, for Appellee.

Argued before: Shaw, Albright, Deborah S. Eyler (Senior Judge, Specially Assigned), JJ.


This is the second appeal in a dispute between Potomac Edison Company ("Potomac Edison"), appellant and cross-appellee, and the Comptroller of Maryland ("Comptroller"), appellee and cross-appellant, over whether Potomac Edison is entitled to a refund of Maryland sales and use taxes. In the first appeal, we vacated the judgment of the Circuit...

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