Boston & Maine Corp. v. State Tax Assessor

[¶ 1] Both the defendant, the State Tax Assessor, and the plaintiff Railroads, Boston <& Maine Corporation and Portland Terminal Company, appeal from a summary judgment entered in the Superior Court (Kennebec County, Harden, J.) in favor of the Assessor on the Railroads’ petition for review of the Assessor’s decision denying certain expenditures as eligible for inclusion in calculating the Railroads’ Maine Capital Tax Credit pursuant to M.R. Civ. P. 80C. Although we do so on alternate grounds, we affirm the judgment of the Superior Court.

I. BACKGROUND

[¶ 2] The parties do not dispute the…