Greenfield v. Commissioner of Revenue

The plaintiff’s testator was, at the time of his death in 1973, the owner of a substantial block of the common stock of a publicly held corporation. On April 5, 1977, the Commissioner of Corporations and Taxation, acting under the provisions of G. L. c. 65, § 25 (as amended through St. 1971, c. 555, § 58), valued the stock at $3,507,823 for purposes of the inheritance tax.1 On June 20, 1977, the State Tax Commission (Commission), apparently *487acting under the provisions of G. L. c. 65, § 26 (as appearing in St. 1961, c. 469, § 3), reduced the valuation to $3,472,351.30.

The plaintiff did not…