Leonardi v. State Tax Commission

The appellant Leonardi, in March, 1967, applied to the State Tax Commission for an abatement of an income tax assessed in August, 1965, on income allegedly received in 1951. The commission disallowed the application on March 14, 1967; Leonardi appealed to the Appellate Tax Board, filing a petition under the formal procedure. The commission filed a plea in bar asserting lack of jurisdiction because the application had not been filed within the time allowed by statute; the board sustained the plea and dismissed the appeal; Leonardi appealed to this court under G. L. c. 58A, § 13.

We state the…