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REPORTED IN THE COURT OF SPECIAL APPEALS OF MARYLAND No. 2875 September Term, 1999

MR. PIZZA II, INC. v. COMPTROLLER OF THE TREASURY

Kenney, Adkins, Wenner, William W., (Retired, specially assigned) JJ.

Opinion by Wenner, J.

Filed: November 28, 2001

The genesis of this appeal is a judgment entered by the Circuit Court for Anne Arundel County affirming a decision of the Maryland Tax Court. Appellant, Mr. Pizza II, Inc. ("Mr. Pizza"), contends that because appellee, the Comptroller of the Treasury (the Comptroller), did not mail a notice of assessment within six months after receiving notice of a bulk sales transfer, the six-month limitations period set forth in

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Maryland Law