State Street Boston Corp. v. Commissioner of Revenue

As in the case of Tilcon Massachusetts, Inc. v. Commissioner of Rev., ante 264 (1991), the taxpayer, State Street Boston Corporation (“State Street”), realized that by reason of an Appellate Tax Board decision made February 27, 1987 (later affirmed in General Elec. Co. v. Commissioner of Rev., 402 Mass. 523 [1988]), it was entitled to a refund of 1984 corporate excise taxes. State Street computed the amount of the refund at $334,150. Under G. L. c. 62C, § 37, the last day for filing State Street’s return was March 15, 1985, and, accordingly, the last day for making application for abatement…