CORDY, J.
This case presents challenges to the Commissioner of Revenue's central valuations, made pursuant to G. L. c. 59, § 39 (§ 39), of the "machinery, poles, wires and underground conduits, wires and pipes" (§ 39 property) of the taxpayer telephone companies for fiscal year (FY) 2004, FY 2005, and FY 2006. In deciding those challenges, we must resolve several issues including (1) whether the Appellate Tax Board (board) correctly upheld the commissioner...
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