SAIC does not appeal that decision. The Comptroller noted a timely appeal to the Court of Special Appeals. This Court granted certiorari on its own initiative prior to any decision of the intermediate appellate court to consider whether the Tax Court erred in exercising jurisdiction to hear and decide SAIC's motion to compel payment of interest, whether SAIC's motion was barred by res judicata, and whether the Tax Court erred in requiring the Comptroller to pay interest on the refund due to SAIC. Comptroller v. Science Applications, 402 Md. 355, 936 A.2d 852 (2007). II.