Leger v. Commissioner of Revenue

The plaintiff, Walter R. Leger, filed a complaint in the Worcester Superior Court seeking declaratory and injunctive relief from a tax lien attached to his residence by the Department of Revenue (department) to secure payment of taxes allegedly owed by Leger. In Count I, Leger sought a declaration that the cost of labor in reupholstering furniture, a commercial activity in which he engaged, is a service which is not subject to the sales tax under G. L. c. 64H, §§ 1 and 2 (1994 ed.). In Count II, Leger alleged that the placing of a lien on his residence prior to a judicial *169hearing was in…