BRAUCHER, J.
Under G.L.c. 59, §§ 64, 65, a taxpayer may appeal to the Appellate Tax Board (board) from a refusal of an application for abatement of a tax of more than $1,500 on a parcel of real estate if he has paid "a sum not less than the amount which would be assessable in the year of assessment of the tax upon a valuation equal to the average of the valuations of said parcel, as reduced by reason of abatements, if any, for the three years next preceding...
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