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TENNECO INC. v. COMMISSIONER OF REVENUE

No. 00-P-1864.

57 Mass. App. Ct. 42 (2003)

TENNECO INC. v. COMMISSIONER OF REVENUE.

Court of Appeals of Massachusetts, Suffolk.

January 9, 2003.

Attorney(s) appearing for the Case

Maxwell D. Solet for the taxpayer.

Daniel J. Hammond, Assistant Attorney General, for Commissioner of Revenue.

Present: GREENBERG, SMITH, & GELINAS, JJ.

GREENBERG, J.

For the years 1981 through 1984, Tenneco Inc. (Tenneco)1 claimed exemption from income tax liability for management fees received from its subsidiaries on the ground that the term "net income," as used in G. L. c. 63, § 52A(2), does not encompass the "paper revenue" it derived from services it performed as a parent corporation.2 The Commissioner of Revenue (commissioner) did not agree. He...

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