Tambrands, Inc. v. Commissioner of Revenue

Tambrands, Inc. (Tambrands), the taxpayer, claims it is entitled to an abatement of all of a deficiency tax assessment because the Commissioner of Revenue (commissioner) failed to give it a timely written notice of assessment as required by G. L. c. 62C, § 31. We decide, as did the Appellate Tax Board (board), that, in the circumstances, the commissioner gave a timely notice of assessment.

That the commissioner furnished the taxpayer with a notice of assessment is not in dispute. The question is whether the commissioner gave the notice, in the language of § 31, “as *523soon as may be,” after the…