dissenting:
The majority holds that, when two individuals purchase property and pay the transfer and recordation taxes,1 and when shortly afterwards they form a corporation and transfer the property to their wholly owned corporation, the second transfer to their corporation is also subject to transfer and recordation taxes. Under the majority’s holding, what is essentially one overall transaction becomes subject to double taxation. Because I believe that the General Assembly did not intend this result, I dissent.
George and Jane Dean bought two parcels of real estate in 1984. The first, known as “Buck-Bacchus House,” was purchased on January 2, 1984, for $130,000. The record in this case shows that the deed to the property was recorded on January 3, 1984, and that substantial transfer and recordation taxes, based on the $130,000 consideration, were duly paid. The other parcel, involving two tracts known as “Hotel Imperial Property” and “Hotel Imperial Stable Property,” was acquired by the Deans on April 15, 1984, for $175,000. Again, the record in this case shows that the deed to this parcel was recorded on May 1, 1984, and that the transfer and recordation taxes, based on the $175,000 consideration, were duly paid.
Three days later, on May 4, 1984, the Deans formed a corporation, of which they were the sole shareholders. Each of the Deans owned 50% of the outstanding shares of stock. Subsequently, the Board of Directors resolved that the corporation would borrow money to renovate the two parcels which the Deans had just purchased. The Deans then deeded the properties to their corporation, receiving nothing in return.
*167The grant from the Deans to the corporation merely-changed the form of ownership of the properties. While technically the corporation is a distinct legal entity, as a practical matter the Deans are the corporation. They are the sole shareholders of a corporation formed exclusively for the purpose of renovating and managing the properties. Looking to the substance of the matter, no “transfer” occurred within the meaning of the statutes.
If the Deans were to purchase the properties in January and April of 1984, they had to do so as individuals, transferring it later to their subsequently-formed corporation. Had the corporation been in existence in January and April, it could have purchased the property, thus necessitating the payment of only one set of transfer and recordation taxes. But simply because the corporation was not formed first, the majority holds that the transaction is taxable twice.
Other courts, under similar circumstances, have concluded that transactions of this nature are exempt from taxes imposed upon the transfer of property. For example, in Senfour Investment Co. v. King County, 66 Wash.2d 67, 401 P.2d 319 (1965), three individuals purchased property prior to the formation of a corporation. After the corporation was formed, the individuals transferred the property by quitclaim deed to the corporation. The Washington Supreme Court pointed to the trial court’s finding that “there was no intent on the part of [the individuals] to do more than hold the naked contract interest for the benefit of the plaintiff corporation when formed.” 66 Wash.2d at 68, 401 P.2d at 320. Consequently, the court concluded that “[s]uch a conveyance is not a sale for a valuable consideration, as required by the statute.” 66 Wash.2d at 70, 401 P.2d at 321.
Similarly, in Wetherbee v. State, 132 Vt. 165, 315 A.2d 251 (1974), two individuals (husband and wife) owned the premises of their business. The Wetherbees applied for a bank loan in order to obtain funds to make business improvements. The bank approved the loan on the condition that the business property be transferred to the corpora*168tion. The Wetherbees transferred the property to the corporation, which transferred it to the bank to secure the loan. The State sought to tax the initial transfer from the Wetherbees to the corporation, conceding, however, that the statute exempted the transfer from the corporation to the bank as a transfer “to secure a debt or other obligation.” 132 Vt. at 167, 315 A.2d at 253. The Vermont Supreme Court concluded that the state took “too mechanical a view of the taxing statute.” 132 Vt. at 168, 315 A.2d at 253. The court continued (ibid.):
“If the tax is to be enforced according to its substantive import, the tax department must not be confined to the labels on the transactions____
“If the tax burden is to be justly imposed, there must be a ... right in the taxpayer to establish that an apparently taxable transfer is, in substance, eligible for exemption.
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“Once the facts establish, as they do here, that the transfer is to secure a debt, the exemption applies.”
See also River Park Joint Venture v. Dickinson, 303 So.2d 654 (Fla.Dist.Ct.App.1974). But cf. Columbia Realty Venture v. Dist. of Columbia, 433 A.2d 1075 (D.C.1981).2
The majority concludes that because the corporation is an entity separate and distinct from the Deans, a taxable transfer occurred.3 This analysis places form over sub*169stance and leads to unjust results. It is a settled rule that a court should not extend a taxing statute beyond the “clear import of the language used.” Comptroller v. John C. Louis Co., 285 Md. 527, 539, 404 A.2d 1045, 1053 (1979). As we went on to state in that opinion (ibid.): “In case of doubt, tax statutes are construed ‘most strongly against the government, and in favor of the citizen.’ ” See Comptroller of the Treasury v. Mandel Re-Election Comm., 280 Md. 575, 580, 374 A.2d 1130, 1132 (1977); Comptroller of the Treasury v. M.E. Rockhill, Inc., 205 Md. 226, 234, 107 A.2d 93, 98 (1954); Magruder v. Hospelhorn, 173 Md. 62, 72, 194 A. 839, 844 (1937). See also Gould v. Gould, 245 U.S. 151, 38 S.Ct. 53, 62 L.Ed. 211 (1917).
It is also a long-established principle that, whenever possible, tax statutes should not be construed and applied so as to result in double taxation. See, e.g., Maass v. Higgins, 312 U.S. 443, 449, 61 S.Ct. 631, 634, 85 L.Ed. 940 (1941) (“if it [double taxation] had been intended, Congress unequivocally would have so declared”); United States v. Supplee-Biddle Hardware Co., 265 U.S. 189, 195-196, 44 S.Ct. 546, 548, 68 L.Ed. 970 (1924) (“The result of the construction put by the Government ... would be to impose a double tax____ Such a duplication, even in an exigent war tax measure, is to be avoided, unless required by express words”); State of Tennessee v. Whitworth, 117 U.S. 129, 137, 6 S.Ct. 645, 647, 29 L.Ed. 833 (1886) (“Double taxation is, however, never to be presumed____ Sometimes tax laws have that effect, but if they do it is because the legislature has unmistakably so enacted. All presumptions are against such an imposition”); Co. Com’rs v. Far. & Mech. Nat. B’k., 48 Md. 117, 121 (1878); State v. Sterling, 20 Md. 502, 520 (1864); Forman v. Commissioner of Internal Revenue, 199 F.2d 881, 883 (9th Cir.1952); Estate of Rose, 465 Pa. 53, 348 A.2d 113, 118 (1975); 3A Sutherland Statutory Construction § 66.01, at 288 (N. Singer 4th ed. 1986). See also Wilkens *170Co. v. Baltimore City, 103 Md. 293, 312-313, 63 A. 562 (1906) . The present case involves one overall transaction of the Deans purchasing property and arranging for its improvement, all during the first half of 1984. Substantial transfer and recordation taxes were paid, based upon the actual consideration of $305,000. It is unreasonable to discern a legislative purpose that this transaction be taxed twice. The “actual consideration paid” upon the transfer was $305,000 and not $610,000.
The majority’s mechanical application of the statutes could lead to absurd results. For example, the majority’s rationale applies equally to the situation where a married couple holds property as tenants in common and later conveys the property to themselves as tenants by the entirety. As in the instant case, the parties would not be merely transferring the property to themselves as individuals but would be transferring it to a somewhat distinct legal entity, the marital unit. As pointed out by Judge Cole for the Court in Beall v. Beall, 291 Md. 224, 234, 434 A.2d 1015 (1981), when a husband and wife signed an agreement as tenants by the entirety, they signed “not in their purely individual capacities but as a team.” See, e.g., Arbesman v. Winer, 298 Md. 282, 292, 468 A.2d 633, 638 (1983) (they “hold by the entirety and not by the moieties”); State v. Friedman, 283 Md. 701, 705, 393 A.2d 1356, 1358 (1978); Picking v. Yates, 265 Md. 1, 2, 288 A.2d 146, 147 (1972) (“they hold per tout et non per my ”); Brewer v. Bowersox, 92 Md. 567, 572-573, 48 A. 1060, 1062-1063 (1901); McCubbin v. Stanford, 85 Md. 378, 390, 37 A. 214 (1897). See also 4 Thompson on Real Property § 1784, at 52-55 (1961). Each would be obtaining a degree of limited liability. See Lake v. Callis, 202 Md. 581, 588, 97 A.2d 316, 319 (1953); Keen v. Keen, 191 Md. 31, 37, 60 A.2d 200, 204 (1948); Jordan v. Reynolds, 105 Md. 288, 294, 66 A. 37, 38 (1907). Therefore, under the majority’s analysis, a conveyance by two tenants in common to themselves as tenants by the entirety would be taxable as a transfer from two individuals to a separate legal entity.
*171I would look to the substance rather than the form of the transaction and would hold that, under the circumstances of this case, the corporation’s acquisition of the property was not a second taxable transfer.
Judges COLE and ADKINS have authorized me to state that they concur with the views expressed herein.
. See Maryland Code (1957, 1980 Repl.VoI.), §§ 277, 278A.
. The majority in the instant case places strong reliance on the Columbia Realty decision. While the opinion in Columbia Realty does tend to support the majority’s position, there is no indication from the opinion that Columbia Realty involved double taxation like that present in the case at bar.
. The majority places great emphasis on the fact that, when the Deans conveyed the properties to the corporation, “the Deans obtain limited personal liability for any corporate obligations with respect to the properties." The record, however, does not fully support this contention. The tax court transcript of proceedings reveals that Mercantile Safe Deposit and Trust, the construction and permanent lender to the corporation, required individual guarantees from the Deans. Thus, with respect to their primary liability, the Deans were personally *169liable and did not enjoy the benefits of limited personal liability generally enjoyed by shareholders of a corporation.