The Massachusetts Appeals Court found that PelleVerde Capital was not entitled to a solar tax exemption for tax years 2015 through 2017 because the company’s solar output was used to power eight municipal properties, which were all tax exempt.

According to the opinion, PelleVerde owned a 1,868.24-kilowatt solar power facility in West Bridgewater, Massachusetts, during the years in question. The company entered into a contract with the town in 2011 to sell all of the solar power facility’s electricity, or net metering credits, to the town. West Bridgewater elected to allocate those credits to power a school, the highway department, the water department, the police department, the town hall, the library, and other municipal properties.