Tenneco Inc. v. Commissioner of Revenue

For the years 1981 through 1984, Tenneco Inc. (Tenneco)1 claimed exemption from income tax liability for management fees received from its subsidiaries on the ground that the term “net income,” as used in G. L. c. 63, § 52A(2), does not encompass the “paper revenue” it derived from services it performed as a parent corporation.2 The Commissioner of Revenue (commissioner) did not agree. He issued a determination letter in which he concluded that Tenneco owed deficiencies in excess of $7.5 million3 for the four years in question. Tenneco, in turn, paid the full amount of the assess*43ments and…