Greenery Securities Corp. v. Commissioner of Revenue

The Commissioner of Revenue (commissioner) appeals, pursuant to G. L. c. 58A, § 13, from a decision of the Appellate Tax Board (board) granting Greenery Securities Corporation (taxpayer or Greenery Securities) an abatement of corporate excise taxes assessed for the tax years 1988, 1989, and 1990.1 The board concluded that certain short-term notes held by the taxpayer qualified as “securities,” were held for *71investment, and did not disqualify the taxpayer as a “security corporation” under G. L. c. 63, § 38B. Accordingly, the taxpayer was entitled to preferential corporate excise tax treatment…