ABRAMS, J.
Pursuant to G. L. c. 58A, § 13 (1998 ed.), the taxpayer appeals from a decision of the Appellate Tax Board (board). The board affirmed the Commissioner of Revenue's (commissioner) denial of the taxpayer's application for abatement of its 1989 corporate excise taxes. The taxpayer, Bill DeLuca Enterprises, Inc. (DeLuca), is a New Hampshire corporation qualified to do business in Massachusetts.
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