Albert Ceccone said yesterday that Neal Potter, his Democratic opponent in the race for Montgomery County executive, is part of the "tax more, spend more, tax more" rule that has dominated the county for 20 years.

Ceccone, a Chevy Chase real estate investor and developer, said that Potter's upset in last week's Democratic primary of incumbent Sidney Kramer places Ceccone in position to pull off his own upset.

Ceccone was the only Republican to enter the race for county executive, and he declared at a morning news conference yesterday that he is in the race "as a serious and dedicated candidate."

He denied rumors that he had been approached by GOP party leaders to drop out of the race so that another Republican, with fewer perceived liabilities, could replace him.

Ceccone has never held public office and has waged a succession of losing campaigns for political office, including a 1984 bid for Congress and a 1986 bid for the GOP county executive nomination. Republicans are traditionally outnumbered in the county and have not captured a spot on the County Council in 20 years.

"It's a whole new, different ballgame now," said state GOP Chairman Joyce L. Terhes, arguing that Ceccone's prospects are improved by not facing an incumbent. Terhes said state party leaders plan to meet with Ceccone to see if they can help.

Ceccone, reading from a statement, said there are sharp differences between him and Potter on taxes and development.

Potter has voiced support for a local gasoline tax, increases in the local piggyback income tax and imposition of taxes on development and parking spots.

"We cannot afford Neal Potter as our county executive," said Ceccone, who said he would hold the line on taxes. During the 1986 campaign, Ceccone was the only candidate to say a tax increase would be necessary, but he now says one can be avoided by strictly controlling development.

Potter responded that it is easy for Ceccone to make promises about improving services and cutting taxes. "He can make easy promises, but I am looking at the arithmetic," Potter said.