Montgomery County challenged a class action seeking refunds of a county tax imposed in connection with solid-waste disposal. The trial court granted summary judgment to the taxpayers and denied the County’s cross-motion after the parties submitted stipulated facts and competing statutory arguments. The Court of Appeals held that the trial court had not completed the required analysis of which County expenditures qualified under the statute’s express exclusions and limitations. The opinion examined the statutory structure and rejected an interpretation that treated the general language of the tax as overriding specific exclusions for particular services. Because the trial court’s ruling rested on an incomplete application of the statutory scheme, the appellate court reversed the grant of summary judgment to the plaintiffs. It remanded for further proceedings, including consideration of the statutory requirements and the County’s remaining arguments. The court did not decide the ultimate amount of any refund or hold that the taxpayers were categorically barred from recovery. Two judges concurred.