Mezzanine Capital Corp. v. Commissioner of Revenue

For the calendar years ending in 1987, 1988, and 1989, Mezzanine Capital Corporation (taxpayer) filed its Massachusetts tax returns and determined its tax as a domestic security corporation, see G. L. c. 63, § 38B, as in effect prior to St. 1992, c. 133, §§ 405-406,1 a favorable status granted to the taxpayer by the Commissioner of Revenue *57(commissioner) on September 25, 1987.2 After an audit of the taxpayer’s returns for the years indicated above, the commissioner assessed additional taxes and, on February 10, 1992, the taxpayer paid the Commissioner the assessed tax of $688,452, together…