Legal Opinion

National Grid Holdings, Inc. v. Commissioner of Revenue

Massachusetts Appeals Court

Decided June 8, 2016No. AC 14-P-1662PublishedCited by 1 opinion

1Opinion of the CourtCypher, J.

The plaintiffs, National Grid Holdings, Inc. (NGHI), National Grid USA (NGUSA), and National Grid USA Service Company, Inc. (NG Service) (collectively, taxpayers), appeal from a decision of the Appellate Tax Board (board) in favor of the defendant, Commissioner of Revenue (commissioner), on the taxpayers’ claims for an abatement of corporate excise for the tax year ended March 31, 2002. Primarily at issue is whether certain financing transactions, referred to as deferred subscription arrangements (DSAs), among various subsidiaries of National Grid pic (NGPLC), constituted true indebtedness so…

2Cases cited34 opinions

  1. United States v. SeckingerSupreme Court of the United States · 1970
  2. Fashion House, Inc. v. K Mart Corporation, Fashion House, Inc. v. K Mart CorporationCourt of Appeals for the First Circuit · 1989
  3. Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
  4. Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
  5. Robert Industries, Inc. v. SpenceMassachusetts Supreme Judicial Court · 1973

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3Cited by1 opinion

  1. National Grid USA Service Co., Inc. v. Commissioner of RevenueMassachusetts Appeals Court · 2016

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