KAPLAN, J.
We affirm a decision of the Appellate Tax Board holding that the taxpayer herein exceeded the time limit prescribed by statute for filing its applications for abatement of the net worth measure of its corporate excise and that, accordingly, the Commissioner of Revenue (commissioner) correctly denied the applications.
The taxpayer, Dana Lease Finance Corp. (DLF), classified as a "foreign," "intangible property" corporation, filed returns reporting...
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