General Electric Co. v. Commissioner, New Hampshire Department of Revenue Administration

The plaintiff, General Electric Company, Inc. (GE), appeals the decision of the Superior Court (Fitzgerald, J.) granting motions filed by the defendant, New Hampshire Department of Revenue Administration (department), to dismiss for lack of standing and for summary judgment. We reverse the grant of the motion to dismiss and affirm the grant of the motion for summary judgment.

The record supports the following facts. This case involves business profits taxes paid by GE from 1990 through 1999 (the tax years). GE is a New York corporation with its principal offices in Connecticut, and with a…