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FARRELL ENTERPRISES, INC. v. COMMISSIONER OF REVENUE.

No. 97-P-1642.

46 Mass. App. Ct. 564 (1999)

FARRELL ENTERPRISES, INC. v. COMMISSIONER OF REVENUE.

Court of Appeals of Massachusetts, Suffolk.

March 30, 1999.

Attorney(s) appearing for the Case

David R. Sullivan (Jeremy Ritzenberg with him) for the taxpayer.

Edward J. DeAngelo, Assistant Attorney General, for the Commissioner of Revenue.

Present: KASS, GILLERMAN, & LAURENCE, JJ.

GILLERMAN, J.

Farrell Enterprises, Inc. (Farrell), a holding company,1 appeals from the refusal of the Commissioner of Revenue (commissioner) to abate, in part, its 1991 corporate excise tax that was assessed under G. L. c. 63, § 39, for the year 1991. The single issue on appeal is whether the net operating losses incurred in taxable years prior to 1991 by three members of...

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