Massachusetts Bay Lines, Inc. v. Commissioner of Revenue

The Legislature provided in an act relative to the construction and financing of convention and exhibition centers in the Commonwealth that any “water-based sightseeing . . . *322or entertainment cruise or tour . . . originating ... in the commonwealth and conducted partly or entirely within the city of Boston” shall be surcharged five percent “on the price of any ticket purchased for” such cruise or tour (convention center financing or CCF surcharge). St. 1997, c. 152, § 9(d), as amended by St. 1999, c. 68, § 17. The taxpayer, Massachusetts Bay Lines (Mass. Bay), provided a variety of…