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NOTES 1137Tax Lawyer, Vol. 60, No. 4NOTEIgnoriIng the EeconomiIc RrealiIty of Llease TtermiInatiIon Ffees iIn Ffavor of an IllogiIcal, PlaiIn MmeaniIng InterpPretatiIon: Comptroller v. CiticCorp Iinternational CommunicCations, IincC. In Comptroller v. Citicorp International Communications, Inc., the Court of Appeals of Maryland held that a termination fee paid by a lessee to a lessor to terminate a computer equipment lease was not subject to sales tax.1 The Maryland court based its holding on its...