FMR Corp. v. Commissioner of Revenue

The sole issue in this appeal is whether the Appellate Tax Board (board) correctly ruled that each corporate entity that files as a member of a Massachusetts “combined” group must deduct its charitable contributions on an individual-entity basis rather than on a consolidated basis, as under the Federal consolidated return regulations. For reasons discussed below, we affirm the decision of the board.

1. Background. The material facts are not in dispute. At all relevant times, FMR Corp. (FMR) was the parent of a group of affiliated corporations that participated in the filing of a Federal…