COMMISSIONER OF REVENUE v. BAYBANK MIDDLESEX


421 Mass. 736 (1996)

COMMISSIONER OF REVENUE vs. BAYBANK MIDDLESEX & others.

Supreme Judicial Court of Massachusetts, Suffolk.

January 24, 1996.


Attorney(s) appearing for the Case

Robert J. Munnelly, Jr., Assistant Attorney General, for Commissioner of Revenue.

Robert M. Buchanan, Jr., for BayBank Middlesex & others.

Louis J. Marett, for the Federal Deposit Insurance corporation, was present but did not argue.

Present: LIACOS, C.J., LYNCH, GREANEY, & FRIED, JJ.


LIACOS, C.J.

In this case, the Appellate Tax Board (board) consolidated 102 appeals and granted to a number of Massachusetts and national banks (banks) abatements totalling $2,688,188.66 from assessments of the bank excise tax, G.L.c. 63, §§ 1 et seq. (1994 ed.), for tax years 1984 through 1990. The Commissioner of Revenue (commissioner) appealed. We granted the banks' application for direct appellate review. We...

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