Dental Service of Mass., Inc. v. Commissioner of Revenue

*804 **304 The taxpayer, Dental Service of Massachusetts, Inc., 1 is an insurer that provides dental coverage through preferred provider arrangements (PPAs). 2 Pursuant to G. L. c. 176I, § 11, insurers operating PPAs are obligated to pay annually an excise **305 tax equal to a specified percentage "of the gross premiums received during the preceding calendar year for coverage of covered persons residing in this [C]ommonwealth" (emphasis added). The term "[c]overed person" is defined in the statute as "any policy holder or other person on whose behalf the organization is obligated to pay for or…