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COMPTROLLER v. FIRST UNITED BANK

No. 100, September Term, 1988.

320 Md. 352 (1990)

578 A.2d 192

COMPTROLLER OF THE TREASURY, INCOME TAX DIVISION v. FIRST UNITED BANK & TRUST AS GUARDIAN FOR THE PROPERTY FOR DALE W. ALEXANDER.

Court of Appeals of Maryland.

August 30, 1990.

Attorney(s) appearing for the Case

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

Harry D. Shapiro (Richard G. Solomon, Weinberg and Green, all on brief), Baltimore, for appellee.

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

ELDRIDGE, Judge.

This Maryland income tax case involves a distribution to a shareholder made in 1985 by a money market mutual fund. The mutual fund's income from which the distribution was made was derived in two ways. One source (accounting for 53.55% of the income) was interest paid by the United States directly to the mutual fund as a holder of federal debt obligations. The other source of the distribution (accounting for 46.45% of the income) was income earned...

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