MENCHINE, J., delivered the opinion of the Court.
The Swarthmore Company (Swarthmore), a Maryland corporation, in its State income tax returns for the years 1971, 1972 and 1973 claimed as deductions from taxable income certain items of interest income, relying upon Maryland Code Article 81, § 280A (c) (4) (1975 Repl. Vol.) as the same existed during the years covered by the returns. The Comptroller disallowed the deduction and assessed a deficiency in the amount...
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