three-fold test in Maryland

1986In reviewing those findings, we enunciated what we consider the proper three-fold analysis which was set forth by the Court of Appeals in Ramsay, Scarlett & Co. v. Comptroller, 302 Md. 825 , 490 A.2d 1296 (1985).

1986In reviewing those findings, we enunciated what we consider the proper three-fold analysis which was set forth by the Court of Appeals in Ramsay, Scarlett & Co. v. Comptroller, 302 Md. 825 , 490 A.2d 1296 (1985).

1979Some of the more recent cases have repeated a so-called “three fold test” initially set forth in Markoff v. Kreiner, 180 Md. 150, 155-156 , 23 A.2d 19 (1941): “Accordingly the three fold test for determining whether a prior or contemporaneous oral agreement between the parties to a written contract is admissible as a collateral agreement is: (1) whether it is an independent collateral agreement separate and distinct from the main contract; (2) whether it is consistent with the provisions of the contract; and (3) whether it is such an agreement as the parties could not reasonably be expected to

1979Some of the more recent cases have repeated a so-called “three fold test” initially set forth in Markoff v. Kreiner, 180 Md. 150, 155-156 , 23 A.2d 19 (1941): “Accordingly the three fold test for determining whether a prior or contemporaneous oral agreement between the parties to a written contract is admissible as a collateral agreement is: (1) whether it is an independent collateral agreement separate and distinct from the main contract; (2) whether it is consistent with the provisions of the contract; and (3) whether it is such an agreement as the parties could not reasonably be expected to

1973In Rinaudo v. Bloom, 209 Md. 1, 9-10 , 120 A. 2d 184 (1956), Chief Judge Brune, for the Court, said: “In Markoff v. Kreiner, supra [ 180 Md. 150 , 23 A. 2d 19 (1941)], and Kikas v. Baltimore County, 200 Md. 360 , 89 A. [2d] 625 [1952], a three-fold test of what constitutes a ‘collateral’ agreement is stated.

1956In Markoff v. Kreiner, supra, and Kikas v. Baltimore County, 200 Md. 360 , 89 A. 625 , a three-fold test of what constitutes a “collateral” agreement is stated. ' Under *10 this test it is necessary (1) that the agreement be independent, separate and distinct from the original agreement, (2) that it be consistent with the provisions of that contract and (3) that it be such an agreement as the parties could not reasonably be expected to embody in the main contract and would naturally make a separate agreement.

1973In Rinaudo v. Bloom, 209 Md. 1, 9-10 , 120 A. 2d 184 (1956), Chief Judge Brune, for the Court, said: “In Markoff v. Kreiner, supra [ 180 Md. 150 , 23 A. 2d 19 (1941)], and Kikas v. Baltimore County, 200 Md. 360 , 89 A. [2d] 625 [1952], a three-fold test of what constitutes a ‘collateral’ agreement is stated.

1971In that case, we read together two contracts entered into with different parties by Shore-ham Developers, Inc. Spector says, and we are inclined to agree, that Perma’s letters met the three-fold test set out in Rinaudo v. Bloom, 209 Md. 1 , 120 A. 2d 184 (1956) by which the existence of a collateral agreement is determined: “Under this test it is necessary (1) that the agreement be independent, separate and dis *558 tinct from the original agreement, (2) that it be consistent with the provisions of that contract and (3) that it be such an agreement as the parties could not reasonably be expect

1986House, was an ‘officer’ which the Legislature intended to impose liability on under Article 81, Section 312(h)(4)(l).” Standard of Review This Court’s recent decisions of Cardellino v. Comptroller, 68 Md.App. 332 , 511 A.2d 573 (1986); Matthew Bender & Co. v. Comptroller, 67 Md.App. 693 , 509 A.2d 702 (1986); and Comptroller v. World Book Childcraft International, Inc., 67 Md.App. 424 , 508 A.2d 148 (1986), enunciate “what we consider the proper three-fold analysis,” Matthew Bender, 67 Md.App. at 705 , 509 A.2d at 708 , that applies to appellate review of a tax court’s decision.

1986House, was an ‘officer’ which the Legislature intended to impose liability on under Article 81, Section 312(h)(4)(l).” Standard of Review This Court’s recent decisions of Cardellino v. Comptroller, 68 Md.App. 332 , 511 A.2d 573 (1986); Matthew Bender & Co. v. Comptroller, 67 Md.App. 693 , 509 A.2d 702 (1986); and Comptroller v. World Book Childcraft International, Inc., 67 Md.App. 424 , 508 A.2d 148 (1986), enunciate “what we consider the proper three-fold analysis,” Matthew Bender, 67 Md.App. at 705 , 509 A.2d at 708 , that applies to appellate review of a tax court’s decision.

1986House, was an ‘officer’ which the Legislature intended to impose liability on under Article 81, Section 312(h)(4)(l).” Standard of Review This Court’s recent decisions of Cardellino v. Comptroller, 68 Md.App. 332 , 511 A.2d 573 (1986); Matthew Bender & Co. v. Comptroller, 67 Md.App. 693 , 509 A.2d 702 (1986); and Comptroller v. World Book Childcraft International, Inc., 67 Md.App. 424 , 508 A.2d 148 (1986), enunciate “what we consider the proper three-fold analysis,” Matthew Bender, 67 Md.App. at 705 , 509 A.2d at 708 , that applies to appellate review of a tax court’s decision.

1986House, was an ‘officer’ which the Legislature intended to impose liability on under Article 81, Section 312(h)(4)(l).” Standard of Review This Court’s recent decisions of Cardellino v. Comptroller, 68 Md.App. 332 , 511 A.2d 573 (1986); Matthew Bender & Co. v. Comptroller, 67 Md.App. 693 , 509 A.2d 702 (1986); and Comptroller v. World Book Childcraft International, Inc., 67 Md.App. 424 , 508 A.2d 148 (1986), enunciate “what we consider the proper three-fold analysis,” Matthew Bender, 67 Md.App. at 705 , 509 A.2d at 708 , that applies to appellate review of a tax court’s decision.

1986House, was an ‘officer’ which the Legislature intended to impose liability on under Article 81, Section 312(h)(4)(l).” Standard of Review This Court’s recent decisions of Cardellino v. Comptroller, 68 Md.App. 332 , 511 A.2d 573 (1986); Matthew Bender & Co. v. Comptroller, 67 Md.App. 693 , 509 A.2d 702 (1986); and Comptroller v. World Book Childcraft International, Inc., 67 Md.App. 424 , 508 A.2d 148 (1986), enunciate “what we consider the proper three-fold analysis,” Matthew Bender, 67 Md.App. at 705 , 509 A.2d at 708 , that applies to appellate review of a tax court’s decision.

1986House, was an ‘officer’ which the Legislature intended to impose liability on under Article 81, Section 312(h)(4)(l).” Standard of Review This Court’s recent decisions of Cardellino v. Comptroller, 68 Md.App. 332 , 511 A.2d 573 (1986); Matthew Bender & Co. v. Comptroller, 67 Md.App. 693 , 509 A.2d 702 (1986); and Comptroller v. World Book Childcraft International, Inc., 67 Md.App. 424 , 508 A.2d 148 (1986), enunciate “what we consider the proper three-fold analysis,” Matthew Bender, 67 Md.App. at 705 , 509 A.2d at 708 , that applies to appellate review of a tax court’s decision.

1980Citing Oklahoma Press, Judge Levine in Banach, 277 Md. at 506 , stated for this Court that the test is, “Whether the inquiry is authorized by statute, the information sought is relevant to the inquiry, and the demand is not too indefinite or overbroad.” Accord Cooper, Federal Agency Investigations: Requirements for the Production of Documents, 60 Mich. L.

1979Terminal, supra, 263 Md. at 558 ; Rinaudo v. Bloom, supra, 209 Md. at 10 .

1979Some of the more recent cases have repeated a so-called “three fold test” initially set forth in Markoff v. Kreiner, 180 Md. 150, 155-156 , 23 A.2d 19 (1941): “Accordingly the three fold test for determining whether a prior or contemporaneous oral agreement between the parties to a written contract is admissible as a collateral agreement is: (1) whether it is an independent collateral agreement separate and distinct from the main contract; (2) whether it is consistent with the provisions of the contract; and (3) whether it is such an agreement as the parties could not reasonably be expected to

1941Bladen v. Wells, 30 Md. 577, 583 ; Basshor v. Forbes, 36 Md. 154 ; Williams v. Kent, 67 Md. 350 , 10 A. 228 ; Roberts v. Bonaparte, 73 Md. 191 , 20 A. 918 , 10 L.

1941Bladen v. Wells, 30 Md. 577, 583 ; Basshor v. Forbes, 36 Md. 154 ; Williams v. Kent, 67 Md. 350 , 10 A. 228 ; Roberts v. Bonaparte, 73 Md. 191 , 20 A. 918 , 10 L.

1941Bladen v. Wells, 30 Md. 577, 583 ; Basshor v. Forbes, 36 Md. 154 ; Williams v. Kent, 67 Md. 350 , 10 A. 228 ; Roberts v. Bonaparte, 73 Md. 191 , 20 A. 918 , 10 L.

1941Bladen v. Wells, 30 Md. 577, 583 ; Basshor v. Forbes, 36 Md. 154 ; Williams v. Kent, 67 Md. 350 , 10 A. 228 ; Roberts v. Bonaparte, 73 Md. 191 , 20 A. 918 , 10 L.

1941Bladen v. Wells, 30 Md. 577, 583 ; Basshor v. Forbes, 36 Md. 154 ; Williams v. Kent, 67 Md. 350 , 10 A. 228 ; Roberts v. Bonaparte, 73 Md. 191 , 20 A. 918 , 10 L.

1941Bladen v. Wells, 30 Md. 577, 583 ; Basshor v. Forbes, 36 Md. 154 ; Williams v. Kent, 67 Md. 350 , 10 A. 228 ; Roberts v. Bonaparte, 73 Md. 191 , 20 A. 918 , 10 L.