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TD BANKNORTH, N.A. v. DEPARTMENT OF TAXES

No. 07-127.

967 A.2d 1148 (2008)

2008 VT 120

TD BANKNORTH, N.A. v. DEPARTMENT OF TAXES.

Supreme Court of Vermont.

September 19, 2008.

Attorney(s) appearing for the Case

Paul P. Hanlon, Montpelier, and John S. Brown of Bingham McCutchen LLP, Boston, Massachusetts, for Plaintiff-Appellant.

William H. Sorrell, Attorney General, and Danforth Cardozo, III, Assistant Attorney General, Montpelier, for Defendant-Appellee.

Present: REIBER, C.J., DOOLEY, JOHNSON, SKOGLUND and BURGESS, JJ.

BURGESS, J.

¶ 1. Taxpayer TD Banknorth, N.A., appeals the determination of the superior court affirming the Commissioner of Taxes' assessment of bank franchise taxes, interest, and penalties against taxpayer for the 2000 and 2001 tax years. In 2000, taxpayer established three holding companies to manage some of the assets of its Vermont banks and to take advantage of favorable tax status for these entities. The superior court agreed with the Commissioner of Taxes...

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