Md. Code, Tax - General § 13–909

(a) Without regard to the provisions of § 13-1104 of this title, if the tax collector determines a person’s financial institution franchise tax or income tax for multiple taxable years and simultaneously finds both overpayments and deficiencies in those taxable years, the tax collector:

(1) may offset the deficiencies to the extent of the overpayments; but

(2) may not allow a refund that is barred under Subtitle 11 of this title.

(b) An overpayment determined under subsection (a) of this section may not be applied as an offset to a deficiency in any taxable year other than the years included in the Comptroller’s determination under subsection (a) of this section.