QUIRICO, J.
This is an appeal by the Belt Realty Corporation (taxpayer) from a decision of the Appellate Tax Board (board) upholding the action of the State Tax Commission (commission) which had denied the taxpayer's application for abatement of a portion of the 1966 excise imposed by G.L.c. 121A, § 10, inserted by St. 1945, c. 654, § 1, and as appearing in St. 1956, c. 640, § 4. The board allowed the assessors of the city of
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