Legal Opinion
National Grid USA Service Co., Inc. v. Commissioner of Revenue
Massachusetts Appeals Court
Decided June 8, 2016No. AC 14-P-1861PublishedCited by 1 opinion
1Opinion of the CourtCypher, J.
National Grid USA Service Company, Inc. (NGUSA), appeals from a decision of the Appellate Tax Board (board) denying its motion for summary judgment and allowing a motion to dismiss brought by the Commissioner of Revenue (commissioner) concerning the effect of a closing agreement between National Grid Holdings, Inc. (NGHI), 1 and the Internal Revenue Service (IRS) on interest deductions under G. L. c. 63, § 30(4). The board rejected National Grid’s position that the closing agreement, which allowed a Federal deduction for a portion of the disputed interest payments, is binding on deductions…
2Cases cited10 opinions
- Lenz v. CommissionerUnited States Tax Court · 1993
- Force v. Department of RevenueOregon Supreme Court · 2011
- Jeffrey G. Sharp v. United StatesCourt of Appeals for the Federal Circuit · 1993
- James J. Flood Joan L. Flood v. United StatesCourt of Appeals for the Ninth Circuit · 1994
- Emily W. DAY, Appellant, v. Margaret HECKLER, Secretary of Health and Human Services, AppelleeCourt of Appeals for the Fourth Circuit · 1984
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3Cited by1 opinion
- National Grid Holdings, Inc. v. Commissioner of RevenueMassachusetts Appeals Court · 2016