DEP'T OF ASSESSMENTS & TAXATION v. LOYOLA FEDERAL S & L ASS'N

No. 1005, September Term, 1988.

79 Md. App. 481 (1989)

558 A.2d 428

STATE DEPARTMENT OF ASSESSMENTS AND TAXATION v. LOYOLA FEDERAL SAVINGS & LOAN ASSOCIATION.

Court of Special Appeals of Maryland.

June 5, 1989.


Attorney(s) appearing for the Case

Kaye Brooks Bushel, Asst. Atty. Gen. (J. Joseph Curran, Jr., Atty. Gen., on the brief), Baltimore, for appellant.

Mark J. Friedman (Piper & Marbury, on the brief), Baltimore, for appellee.

Argued before MOYLAN, BISHOP and ROSALYN B. BELL, JJ.


ROSALYN B. BELL, Judge.

This case presents the question of whether a taxpayer can get a double benefit from a net operating loss because of an ambiguous Maryland franchise tax form. In June of 1988, the Circuit Court for Baltimore City determined that Loyola Federal Savings & Loan Association (Loyola) was entitled to such a deduction. We conclude that no such double benefit is available.

At issue in this appeal is the starting point in the calculation...

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