LIACOS, C.J.
The Commissioner of Revenue (commissioner) has appealed from a decision of the Appellate Tax Board (board), given under the formal procedure, granting Houghton Mifflin Company (Houghton) an abatement equal to Houghton's 1988 investment tax credit. See G. L. c. 63, § 31A (1994 ed.). We allowed the commissioner's application for direct appellate review.
The board concluded that Houghton was eligible for the credit because it was a "manufacturing...
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