WILKINS, J.
The State tax commission appeals from a decision of the Appellate Tax Board granting an abatement to Aetna Life Insurance Company, a Connecticut corporation, upon a part of the taxes paid the Commonwealth under its 1952 excise tax return. G.L. (Ter. Ed.) c. 63, § 20, as appearing in St. 1943, c. 531, § 1. The parties are in agreement that Aetna is taxable on the basis of the net value of policies issued, or assumed, by it and in effect on
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