King v. Comptroller

After the IRS concluded its audit of the Baltimore Orioles Limited Partnership's tax returns for years 1993-1999 and adjusted various partnership items, the personal income tax liability of Wanda King, one of the limited partners, was lessened and she became eligible for a state tax refund totaling $173,364. King filed a claim for refund, but the Comptroller of the Treasury denied it, stating that the refund claim was not timely filed because the IRS's final report regarding adjustments to King's personal tax liability had been issued more than a year before King filed her refund. On appeal, the Maryland tax court ruled in favor of the Comptroller. The circuit court reversed the tax court, and the court of special appeals reversed. The Supreme Court affirmed the court of special appeals, holding (1) the statute of limitations applicable to King's refund claim began to run when the IRS issued to her certain forms on January 3, 2006, and accordingly, King's refund claim had to have been filed within one year of that date; and (2) thus, King's submission on February 2, 2007 was untimely. View "King v. Comptroller" on Justia Law