Supermarkets General Corp. v. Commissioner of Revenue

This appeal raises issues and arises from facts similar to those considered in Electronics Corp. of Am. v. Commissioner of Revenue, ante 672 (1988), also decided today. However, in this case we are presented squarely with a question left open in Electronics Corp. of Am., that is, whether the abatement application of the taxpayer, Supermarkets General Corporation, 1 was timely filed “within two years from the date the tax was assessed or deemed to be assessed” under G. L. c. 62C, § 37 (1986 ed.). A preliminary procedural question is presented as to whether the taxpayer waived its right of…