LYNCH, J.
Northeast Petroleum Corporation (taxpayer) appeals from a decision by the Appellate Tax Board (board) denying an abatement of a tax on the distribution received by the taxpayer upon the liquidation of its fifty per cent owned subsidiary, Energy Corporation of Louisiana (Energy). The board upheld a refusal by the Commissioner of Revenue (Commissioner) to abate the taxpayer's corporate excise for the fiscal year ending June 30, 1977.
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