LENK, J.
A. W. Chesterton Company (Chesterton) appeals from a decision of the Appellate Tax Board (board) favorable to the Commissioner of Revenue (commissioner). The board upheld the commissioner's denial of Chesterton's application to abate its corporate excise tax for the 1982 tax year. Chesterton's abatement application was based, in relevant part, on its contention that the commissioner had not timely assessed the tax and that the limitations period of G. L....
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