Barnes v. State Tax Commission

This bill for declaratory relief relative to the plaintiffs’ tax liabilities under G. L. c. 62, §§ 1-8, as appearing in St. 1971, c. 555, § 5, was reserved and reported by the single justice. The case is here on a record consisting of the bill, the answer, a statement of agreed facts, and certain other papers not material.

The plaintiffs are trustees of the Public Finance Trust (PFT). PFT has been licensed under G. L. c. 140, § 96, by the Commissioner of Banks to engage in the business of making loans of $3,000 or less. From its business activities PFT derives income from interest on the small…