Art. 66-V2, §§ 150 through 179. That statute defined “person” to include “governmental bodies.” UCJF § 150(i). The UCJF definition of “qualified person,” however, was limited to “a resident of this State” or to the owner of a motor vehicle registered in Maryland or in a jurisdiction affording reciprocity to Maryland residents under a similar statute. UCJF § 150(g). The United States does not register its automobiles with any state authorities. The Fourth Circuit held that “[t]he United States as a sovereign is a resident of territorial United States, and we think it not unreasonable to hold the United States to be a resident of every State.” 314 F.2d at 417. . In support, the Fourth Circuit cited Helvering v. Stockholms Enskilda Bank, 293 U.S. 84, 55 S.Ct. 50, 79 L.Ed. 211 (1934) (<HOLDING>); Vaughan v. Northup, 40 U.S. (15 Pet.) 1, 6,
holding that resident shareholder of s corporation is eligible for tax credit for taxes paid by corporation in another state and noting that this conclusion is consistent with the internal revenue code which provides that shareholders of an s corporation are entitled to a foreign tax credit for their share of foreign income tax paid by an s corporation holding that when the united states held a senior tax lien it was an indispensable party under the controlling federal tax law holding that the fourteenth amendment which makes persons bom in the united states and subject to its jurisdiction citizens of the united states and requires that representatives be apportioned among the states based on population excluding indians not taxed did not make an indian a citizen of the united states holding that interest received by a foreign corporation on a tax refund from the united states was interest on an interestbearing obligation of a resident of the united states within income tax statute holding that full payment of the assessment is also required for tax refund suits brought in the united states court of federal claims