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Massachusetts high court rejects claim that single sales factor apportionment formula violates Commerce Clause

The Massachusetts Supreme Judicial Court (MSJC) has affirmed a prior holding of the Massachusetts Appellate Tax Board that the Commonwealth’s apportionment and credit regimes applicable to manufacturing corporations does not violate the Commerce Clause of the U.S. Constitution. The MSJC also held that for the purpose of determining whether the taxpayer was substantially engaged in manufacturing, gross receipts from the redemption of securities were not to be considered.