HOUSEHOLD RETAIL SERVICES, INC. v. COMMISSIONER OF REVENUE


448 Mass. 226 (2007)

HOUSEHOLD RETAIL SERVICES, INC., & another vs. COMMISSIONER OF REVENUE.

Supreme Judicial Court of Massachusetts, Suffolk.

January 16, 2007.


Attorney(s) appearing for the Case

Peter O. Larsen, of Florida (Nicholas J. Rosenberg with him) for the taxpayers.

Amy Spector, Assistant Attorney General, for Commissioner of Revenue.

Present: MARSHALL, C.J., GREANEY, IRELAND, SPINA, COWIN, SOSMAN, & CORDY, JJ.


MARSHALL, C.J.

The sole issue in this appeal is whether a financial services company that contractually obtained a retailer's rights to certain consumer credit accounts is entitled to a reimbursement of sales tax on the consumer accounts subsequently determined to be worthless, pursuant to G. L. c. 64H, § 33 (bad debt statute). Household Retail Services, Inc., and Household Bank (SB), N.A. (collectively Household), appeal from a decision of the Appellate Tax...

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