§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.