General Electric Co. v. Commissioner of Revenue

These three consolidated cases present the following question: Should corporate taxpayers who elect to file a combined Massachusetts tax return under G. L. c. 63, § 32B, first combine their net incomes, then adjust that sum under G. L. c. 63, § 38 (a), to arrive at the group’s taxable net income and, lastly, apportion the group ’ s taxable net income to Massachusetts by using a combined apportionment factor, or should they first separately determine and apportion the taxable net income of each affiliated corporation, -and then combine those sums to arrive at the group’s income taxable in…