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LIBERTY MUTUAL INS. CO. v. COMMISSIONER OF REVENUE

405 Mass. 352 (1989)

541 N.E.2d 566

LIBERTY MUTUAL INSURANCE COMPANY vs. COMMISSIONER OF REVENUE. (and nine companion cases).

Supreme Judicial Court of Massachusetts, Suffolk.

July 11, 1989.

Attorney(s) appearing for the Case

Mark A. Michelson (Samuel B. Bruskin & James F. Whipple with him) for the taxpayers.

Thomas A. Barnico, Assistant Attorney General, for the Commissioner of Revenue.

Edward F. Hines, Jr., & Robert M. Buchanan, Jr., for Baybank Middlesex & others, amici curiae, submitted a brief.

Present: LIACOS, C.J., WILKINS, ABRAMS, LYNCH, O'CONNOR, JJ.

ABRAMS, J.

Liberty Mutual Insurance Company and Liberty Mutual Fire Insurance Company (companies) appeal from a decision of the Appellate Tax Board (board). The board upheld the decision of the Commissioner of Revenue (Commissioner), who denied the companies' applications for abatement on the excise tax imposed on domestic insurance companies by G.L.c. 63, § 22A (1986 ed.).2 The companies argue that the excise tax imposed by G.L.c...

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