Peterson v. Commissioner of Revenue

Article 44 of the Amendments to the Massachusetts Constitution accords the Legislature “a considerable range of discretion within the bounds of reason” to establish classifications of taxable income. Daley v. State Tax Comm’n, 376 Mass. 861, 866 (1978). See Opinion of the Justices, 425 Mass. 1201, 1203 (1997). Taxpayers challenging such classifications bear the heavy burden of proving “beyond a rational doubt,” Andover Sav. Bank v. Commissioner of Revenue, 387 Mass. 229, 235 (1982), that the General Court’s line drawing is “plainly and grossly oppressive and unequal, or contrary to common…