First Data Corp. v. State Tax Commission

General Laws c. 63, § 38C, as appearing in St. 1970, c. 634, § 4, defines a “domestic manufacturing corporation,” rather uninformatively, as one which is “engaged in manufacturing.” Such a corporation is entitled to exemption of its machinery from certain local taxes. G. L. c. 59, § 5, Sixteenth (3) (a). Classification of a corporation is first made by the Commissioner of Corporations and Taxation, with a ladder of review reaching to this court. G. L. c. 58, § 2. In the present case First Data Corporation (taxpayer), which operates an electronic digital computer system in Waltham, was refused…