Commissioner of Revenue v. Northeast Petroleum Corp.

The Commissioner of Revenue (Commissioner) appeals from a decision of the Appellate Tax Board (board) ordering an abatement of $3,311,246.55 plus interest to Northeast Petroleum Corporation (Northeast) on the gain realized from the distribution received on the liquidation of its fifty per cent owned subsidiary, Energy Corporation of Louisiana (Energy). In a prior opinion, we reversed the decision of the board and remanded for further proceedings in light of our opinion in Commissioner of Revenue v. Shafner, 392 Mass. 256 (1984). Northeast Petroleum Corp. v. Commissioner of Revenue, 395 Mass.…