BISHOP, Judge.
This case involves a dispute between appellant Comptroller of the Treasury (Comptroller) and appellee NCR Corporation (NCR) over the assessment of Maryland corporate income taxes. The controversy began in 1976, when the Comptroller assessed NCR with additional Maryland corporate income taxes for the years 1972 through 1974 in the total amount of $30,315.00 plus interest. In 1980, the Comptroller again assessed NCR with additional Maryland corporate...
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