WILKINS, J.
The appellant, an urban redevelopment corporation organized under G.L.c. 121A, was obliged to pay an excise with respect to 1971 and 1972. In the circumstances, the excise was calculated by using the average of the assessed valuation of all real estate on the premises in Boston now owned by the appellant on the three assessment dates next preceding its acquisition by the Boston Redevelopment Authority, from whom in turn the appellant acquired the premises...
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