KATZMANN, J.
This is an appeal from a decision of the Appellate Tax Board (board) affirming the denial by the Commissioner of Revenue (Commissioner) of applications by the taxpayers, The Interface Group (Interface) and Sheldon G. Adelson (Adelson), for the abatement of taxes relating to the sale of travel packages. The taxpayers contend that the board erred in applying the corporate excise sales factor, see G. L. c. 63, §§ 38(c) & 38(f...
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