Geoffrey, Inc. v. Comm'r of Revenue, 453 Mass. 17 (Mass. 2009)

Commonwealth could impose corporate excise tax, pursuant to Mass. Gen. Laws ch. 63, § 39, on the taxpayer, a foreign corporation, that did not have physical presence in Massachusetts; taxpayer met "substantial nexus" test for imposing that tax because it allowed resident companies to use its intangible property to generate income for the taxpayer.
 
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