BLOOM, Judge.
This case involves the validity of an excise tax imposed by Baltimore County on a real estate transfer effected by the filing of Articles of Transfer with the State Department of Assessments and Taxation (hereinafter referred to as the Department) in accordance with Title 3, subtitle 1 of the Corporations and Associations article of the Annotated Code of Maryland (1985 Repl.Vol.).
Hampton Apartments, Inc., a Maryland corporation, sold real estate...
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