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RANDOM HOUSE v. COMPTROLLER

No. 9, September Term, 1987.

310 Md. 696 (1987)

531 A.2d 683

RANDOM HOUSE, INC. v. COMPTROLLER OF THE TREASURY.

Court of Appeals of Maryland.

October 8, 1987.

Attorney(s) appearing for the Case

E. Stephen Derby (Karen L. Myers Zauner and Piper & Marbury, on the brief), Baltimore, for appellant.

John K. Barry, Asst. Atty. Gen. (J. Joseph Curran, Jr., Atty. Gen., Baltimore, and Gerald Langbaum, Asst. Atty. Gen., on the brief), Annapolis, for appellee.

Argued before MURPHY, C.J., and ELDRIDGE, COLE, RODOWSKY, COUCH, McAULIFFE and ADKINS, JJ.

RODOWSKY, Judge.

For taxing the income of corporations carrying on a unitary business in this state and elsewhere, Maryland Code (1957, 1980 Repl. Vol., 1986 Cum.Supp.), Art. 81, § 316 requires that net income be apportioned to this state on the basis of a formula using property, payroll, and sales.1 Applying that formula the Comptroller of the Treasury assessed Random House, Inc. The taxpayer argues that the Comptroller should modify...

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