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BOSTON SAFE DEPOSIT, TRUST v. COMMR OF REVENUE

13 Mass. App. Ct. 492 (1982)

434 N.E.2d 218

BOSTON SAFE DEPOSIT & TRUST COMPANY & another, executors, vs. COMMISSIONER OF REVENUE.

Appeals Court of Massachusetts, Worcester.

April 28, 1982.

Attorney(s) appearing for the Case

Alexander Whiteside (Howard S. Whiteside with him) for the plaintiffs.

Gerald J. Caruso, Assistant Attorney General, for the defendant.

Present: GRANT, GREANEY, & SMITH, JJ.

GRANT, J.

The plaintiffs' testatrix was, at the time of her death in 1974, the owner of a substantial block of an issue of preferred stock of a publicly held corporation. On August 25, 1976, the Commissioner of Corporations and Taxation, acting under the provisions of G.L.c. 65, § 25 (as amended through St. 1971, c. 555, § 58), valued the stock at $765,806.25 for purposes of the inheritance tax.

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