Liberty Life Assurance Co. v. State Tax Commission

We are concerned with whether a domestic insurance company which filed an apparently proper appeal to the Appellate Tax Board (board) under G. L. c. 63, § 71, is nevertheless barred from pursuing that appeal because, at an earlier date and on its own motion, it sought and obtained from the State Tax Commission (commission) an abatement of a portion of its excise on grounds unrelated to its subsequent appeal. We conclude that such a successful applicant for an abatement loses neither its right to seek a subsequent abatement nor, if the abatement is denied, its right to appeal seasonably to the…