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AMERICAN CAS. CO. OF READING, PA. v. DEP'T LICENS. & REG. INS. DIV.

No. 1515, September Term, 1981.

52 Md. App. 157 (1982)

447 A.2d 484

AMERICAN CASUALTY CO. OF READING, PENNSYLVANIA, ET AL. v. DEPARTMENT OF LICENSING AND REGULATION INSURANCE DIVISION.

Court of Special Appeals of Maryland.

Decided July 12, 1982.

Attorney(s) appearing for the Case

William J. Rubin, with whom were Emanuel H. Horn, and Dickerson, Nice, Sokol & Horn on the brief, for appellants.

Thomas P. Barbera, Assistant Attorney General, with whom were Stephen H. Sachs, Attorney General of Maryland and Michael L. Cohen, Assistant Attorney General, on the brief, for appellee.

The cause was argued before LOWE and MASON, JJ., and GEORGE W. BOWLING, Associate Judge of the Seventh Judicial Circuit, specially assigned.

LOWE, J., delivered the opinion of the Court.

Appellants are seven insurance companies doing business in Maryland, all members of what is known as the CNA Group. They are subject to an annual tax imposed by Md. Ann. Code (1980 Repl. Vol.), Art. 81, § 136 (a) upon the percentage of gross direct premiums allocable to Maryland and written during the preceding year. In 1977, § 139 of that article (Code, 1975 Repl. Vol. & 1976 Supp.) provided that insurance...

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