Legal Opinion

Leger v. Adams

Massachusetts Superior Court

Decided July 15, 1994No. 93-2589-APublished

1Opinion of the CourtLenk, J.

The plaintiff, Walter R. Leger (“Leger”), filed this civil action seeking declaratory and injunctive relief from a tax lien filed by the defendant, the Commissioner of Revenue (“the Commissioner”), against Leger’s residence for an unpaid sales tax assessment. In Count I, Leger seeks a declaration that the cost of labor in reupholstering furniture, a commercial activity in which he engages, is a service which is not subject to the sales tax under G.L c. 64, §§1 and 2. Leger seeks a declaration in Count II that the Commissioner’s filing of a tax lien without first providing Leger with an…

2Cases cited18 opinions

  1. Mathews v. EldridgeSupreme Court of the United States · 1976
  2. Boddie v. ConnecticutSupreme Court of the United States · 1971
  3. Calero-Toledo v. Pearson Yacht Leasing Co.Supreme Court of the United States · 1974
  4. United States v. James Daniel Good Real PropertySupreme Court of the United States · 1993
  5. Phillips v. CommissionerSupreme Court of the United States · 1931

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