THOMSEN, Chief Judge.
The comptroller has moved to dismiss the "petition", really a complaint, filed by Jacobs to enjoin the comptroller from collecting sales and use taxes in the amount of $1,914.62, including penalty and interest, assessed against Jacobs under the Maryland Retail Sales Tax and Maryland Use Tax Acts, Ann.Code, art. 81, secs. 320-396, incl. The complaint alleges that Jacobs was not liable for the taxes because the purchases, as a result of which the...
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