GRAINGER, J.
At issue in this case of first impression is the application of the room occupancy excise (tax), G. L. c. 64G, to the first ninety days of rentals that exceeded a ninety-day period. Plaintiffs, Charles and Irene Lowney, own and operate the Carleton Circle Motel (motel) in Falmouth. They appeal the decision of the Appellate Tax Board affirming the denial of their application for tax abatement by the Commissioner of Revenue.
Background. The...
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