payroll, and sales to compute the apportionment factor. Rather, it merely requires a reasonable attribution of a corporation’s income. MD.ANN.CODE art. 81, § 316(c) (1980). To determine what constitutes a reasonable attribution, it is necessary to examine the statutory scheme within which section 316(c) functions. Under this framework, the Comptroller possesses no authority to tax NCR’s foreign subsidiaries either collectively, as a part of NCR’s total business, or individually on a separate return. As to combined returns, article 81, section 295 of the Maryland Code precludes NCR from reporting the income of its foreign subsidiaries as part of its total Maryland taxable income. See Chesapeake Industries, Inc. v. Comptroller of the Treasury, 59 Md.App. 370, 475 A.2d 1224 (1984) (<HOLDING>). As to individual returns, the Constitution
holding that the university of maryland law school was a state agency holding that maryland law prohibits use of combined reporting holding that a maryland court could exercise jurisdiction over an outofstate hospital that provided services to maryland residents and registered as a maryland provider designating itself as a liver transplant referral center holding that state constitution prohibits substantive use of prearrest silence holding that the combined effect of trial counsels errors should be considered