Walter Kidde & Co. v. Commissioner of Revenue

The Commissioner of Revenue (Commissioner) appeals from a decision of the Appellate Tax Board (board) in favor of Walter Kidde & Company, Inc. (Kidde), and two of its wholly owned subsidiaries, General Offset Printing Company, Inc. (GOP), and Craig Systems Corporation (Craig). We affirm the decision of the board.

General Laws c. 63, § 32, imposes an excise on domestic business corporations. General Laws c. 63, § 39, imposes an excise on foreign corporations. The first measure of the excise based on tangible property, was, as the statutes require, separately assessed against each of the three…