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In addition to the functions that we have been
talking about, the State Comptroller exercises two other
functions, neither one of which is administrative. The
Comptroller, when he makes regulations for the divisions
in his office. Sales Tax, Commissions Tax, Income Tax
and the rest, he is exercising a delegated legislative
product, a power delegated him by the legislature.
Likewise, when the Governor or his designee
in his office holds hearings on the questions that are
very often raised as to the application of any tax imposed
by the legislature or questions the applicability to him
of any such tax, the Comptroller or his designee must
make findings of fact and on those facts determine whether
the taxpayer is liable to pay the tax in question. In
doing that, in performing that function, the Comptroller
performs a quasi-judicial power, just the same as any
quasi-judicial board of the State, for instance, the Mary-
land Tax Court performs a quasi-judicial power so that the
State Comptroller is not confined to administrative powers;
he also performs those delegated legislative powers and
quasi-judicial powers.