The Maryland Circuit Court held that an intangible holding company lacked economic substance and therefore was subject to Maryland corporate income tax based on the activities of its corporate parent. The court also upheld the Maryland Comptroller’s use of a “blended” apportionment formula to calculate the intangible holding company’s taxable income attributable to Maryland. The blended apportionment formula included the apportionment factors of five related entities filing returns in Maryland. In the Matter of ConAgra Brands, Inc., No. C-02-CV-15-993 (Md. Cir. Ct. Anne Arundel Cnty. Oct. 19, 2015).