MD. NAT'L BANK v. ST. DEP'T OF ASSESS. AND TAXATION

Nos. 446, 447, September Term, 1983.

57 Md. App. 269 (1984)

469 A.2d 907

MARYLAND NATIONAL BANK v. STATE DEPARTMENT OF ASSESSMENTS AND TAXATION. MARYLAND NATIONAL INDUSTRIAL FINANCE CORPORATION v. STATE DEPARTMENT OF ASSESSMENTS AND TAXATION.

Court of Special Appeals of Maryland.

Certiorari Denied May 28, 1984.


Attorney(s) appearing for the Case

Herman B. Rosenthal, with whom were George D. Hubbard and Semmes, Bowen & Semmes, Baltimore, on brief, for appellants.

Kaye Brooks Bushel, Asst. Atty. Gen., with whom were Stephen H. Sachs, Atty. Gen. and T. Scott Basik, Asst. Atty. Gen., on brief, for appellee.

Argued before MOYLAN, LOWE and GARRITY, JJ.


LOWE, Judge.

"`When I use a word,' Humpty-Dumpty said, in rather a scornful tone, `it means just what I choose it to mean — neither more nor less.'"1

Generally speaking, the term "taxable income" (for purposes of measuring the federal income tax) excludes from a taxpayer's gross income any state "income taxes" which the taxpayer has paid during the taxable year. In 1969, Maryland imposed a "franchise tax"

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