Not Worth the Wait: Reflections on the Maryland Digital Ad Tax Rulings

Darien Shanske (UC Davis), Michael Mazerov & Peter Enrich, Not Worth the Wait: Reflections on the Maryland Digital Ad Tax Rulings, 121 Tax Notes State 957 (Sept. 28, 2026)

In this installment, the authors criticize the Maryland Tax Court’s three recent digital advertising tax decisions, arguing that they fail to even consider the differences between targeted digital advertising and traditional advertising and misunderstand constitutional doctrines, among other flaws.

Previous TaxProf Coverage:

Shanske: Md. Court Got Ad Tax Similarity Analysis Wrong
Maryland Tax Court Invalidates Digital Ad Tax on Constitutional and ITFA Grounds
Maryland Digital Ad Tax Rulings Shift Debate to What Comes Next

About the Author

Andrew D. Appleby

Andrew Appleby is an Associate Professor of Law at the University of Tennessee Winston College of Law. He has particular expertise in state and local taxation, taxation of the digital economy, sports taxation, and applied tax policy. Prior to joining academia, he practiced multistate tax law at leading law firms for a decade, and he now co-authors the State Taxation treatise with Prof. Walter Hellerstein.

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