LYNCH, J.
At issue in this case is whether certain pollution control equipment used by V.H. Blackinton & Co., Inc. (taxpayer), in its manufacturing processes is exempt from the Massachusetts sales tax, pursuant to G.L.c. 64H, § 6 (s) (1992 ed.). In 1984, the Commissioner of Revenue (commissioner) assessed a sales tax on the taxpayer's purchase of the equipment. The taxpayer paid the assessments and filed applications for abatement. The applications...
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