Mass. Gen. Laws ch. 62C, § 36B

The commissioner shall waive or abate any portion of any penalty or addition to tax assessed under this chapter attributable to erroneous advice furnished to the taxpayer in writing by an officer or employee of the department of revenue, acting in such officer's or employee's official capacity, provided that (a) the written advice was reasonably relied upon by the taxpayer and was in response to a specific written request of the taxpayer, and (b) the portion of the penalty or addition to tax did not result from a failure by the taxpayer to provide adequate or accurate information.