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DEPARTMENT OF REVENUE v. ESTATE OF SHEA

No. 06-P-1804.

71 Mass. App. Ct. 696 (2008)

DEPARTMENT OF REVENUE v. ESTATE OF RAYMOND SHEA & another.

Appeals Court of Massachusetts, Suffolk.

May 9, 2008.

Attorney(s) appearing for the Case

Patricia L. Davidson (Robert S. White with her) for the defendants.

Kenneth W. Salinger, Assistant Attorney General, for the plaintiff.

Present: KANTROWITZ, DREBEN, & McHUGH, JJ.

McHUGH, J.

For almost twenty years, the Commonwealth's Department of Revenue (DOR) has been trying to collect taxes owed by Gladys M. Shea (Gladys) and her now-deceased husband, Raymond E. Shea, Sr. (Raymond), for the four taxable years, 1980 through 1983.2 The collection effort has had four distinct phases. The first addressed the propriety of the DOR's assessments. That phase was followed...

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