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COMPTROLLER v. JAMESON

No. 16, September Term, 1993.

332 Md. 723 (1993)

633 A.2d 93

COMPTROLLER OF THE TREASURY v. MARY JAMESON & W. RONALD JAMESON, PERSONAL REPRESENTATIVES OF THE ESTATE OF MARY LOUISE JAMESON.

Court of Appeals of Maryland.

November 22, 1993.

Attorney(s) appearing for the Case

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

John C. Heisler (C. David Heisler, Heisler, Williams & Lazzaro) all on brief, Towson, for appellee.

Argued before MURPHY, C.J., ELDRIDGE, McAULIFFE, CHASANOW, KARWACKI and ROBERT M. BELL, JJ., and CHARLES E. ORTH, Jr., Judge of Court of Appeals (retired), Specially Assigned.

MURPHY, Chief Judge.

We granted certiorari in this case to consider whether the State of Maryland may collect interest on the late payment of Maryland estate taxes where a subsequent payment of Maryland inheritance taxes eliminates the original estate tax liability.

I

This case involves the complex interplay among the Maryland estate tax, the Maryland inheritance tax, and the federal estate tax. Because the terminology is critical to an understanding...

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