WILKINS, J.
Prudential-Bache Securities, Inc. (Prudential), brought this action for interpleader under Mass. R. Civ. P. 22, 365 Mass. 767 (1974), seeking a determination of the relative rights of the defendant Commissioner of Revenue (commissioner) and of the defendants Syed and Gulzar Rahman to the Rahmans' assets that Prudential maintains in joint accounts in an Illinois branch office. The controversy arose when the commissioner, relying on G.L.c. 62C, § 53...
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