South Boston Savings Bank v. Commissioner of Revenue

General Laws c. 63, § 11, as in effect for the tax years ending October 31, 1983, and October 31, 1984 (see 1984 ed.), imposed on every savings bank an excise based in part on “the average amount of [the savings bank’s] deposits or of its savings accounts and share capital . . . after deducting from such average amounts ... the unpaid balances on its loans secured by the mortgage of real estate.” The question presented in this appeal, brought by the Commissioner of Revenue (Commissioner), is whether the statutory language permitting a savings bank to deduct the amounts of “unpaid balances on…