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HOPKINTON LNG CORP. v. STATE TAX COMMISSION

372 Mass. 286 (1977)

362 N.E.2d 205

HOPKINTON LNG CORP. vs. STATE TAX COMMISSION.

Supreme Judicial Court of Massachusetts, Suffolk.

April 1, 1977.

Attorney(s) appearing for the Case

Gerald May for the taxpayer.

Andrew J. McElaney, Jr., Assistant Attorney General, for the State Tax Commission.

Present: HENNESSEY, C.J., BRAUCHER, WILKINS, LIACOS, & ABRAMS, JJ.

BRAUCHER, J.

The taxpayer converts natural gas into a liquid through a refrigeration process, and claims that it is a "manufacturing corporation" under G.L.c. 58, § 2,1 and G.L.c. 63, § 38C.2 It was so classified, but the classification was revoked as of January 1, 1973. The Appellate Tax Board (board) held that the process constitutes a service and not a manufacturing activity, and we affirm. The...

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