The Massachusetts Appellate Tax Board ruled that a company that develops and sells software-as-a-Service (SaaS) is allowed a property tax exemption for the machinery it uses in its development process. The Appellate Tax Board previously ruled that the company was a manufacturing corporation, and thus was entitled to use single sales factor apportionment provided to manufacturing companies for corporate income tax purposes, rather than the standard three-factor formula used by service providers.  Because the Appellate Tax Board classified the company as a manufacturing corporation for corporate income tax purposes, the Board concluded that the company was also entitled to the attendant property tax exemption for the machinery used in conducting its manufacturing business.