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REGISTER OF WILLS FOR BALTIMORE COUNTY v. ARROWSMITH

No. 122, Sept. Term, 2000.

778 A.2d 364 (2001)

365 Md. 237

REGISTER OF WILLS FOR BALTIMORE COUNTY v. Jeffrey A. ARROWSMITH, et al.

Court of Appeals of Maryland.

August 15, 2001.

Attorney(s) appearing for the Case

Julia M. Andrew, Asst. Atty. Gen. (J. Joseph Curran, Jr., Atty. Gen. of Md., on brief), Baltimore, for Appellant.

Kurt J. Fisher (Sandra P. Gohn, Kenneth S. Aneckstein of Piper, Marbury, Rudnick & Wolfe, L.L.P., on brief), Baltimore, for Appellees.

D. Robert Enten, Gordon, Feinblatt, Rothman, Hoffberger & Hollander, L.L.C., Baltimore, on brief of the Maryland Bankers Ass'n, Inc. as Amicus Curiae in support of Appellees.

Argued before BELL, C.J., ELDRIDGE, RAKER, WILNER, CATHELL, HARRELL and BATTAGLIA, JJ.

BATTAGLIA, Judge.

We issued a writ of certiorari in this case to determine whether Maryland's statute of limitations with respect to filing a claim for refund of inheritance taxes was rendered inapplicable by the Treaty ratified pursuant to the Convention Between the United States of America and the Federal Republic of Germany for the Avoidance of Double Taxation with Respect to Taxes on Estates, Inheritance, and Gifts.1

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