Patriot General Life Insurance v. Commissioner of Revenue

Patriot General Life Insurance Company (taxpayer) appeals from a decision of the Appellate Tax Board (board) sustaining the refusal of the Commissioner of Revenue (Commissioner) to abate an investment privilege excise assessed under G. L. c. 63, § 22B, for the taxable year ending December 31, 1978.

From the statement of agreed facts which was adopted by the board the following facts appear. The taxpayer is a domestic life insurance company incorporated under the laws of the Commonwealth. On December 20,1978, it sold its right to receive future interest income on certain bonds for a net payment…