Massachusetts Fire & Marine Ins. Co. v. Com'r of Int. Rev.

L. HAND, Circuit Judge.

The taxpayer, a Massachusetts corporation, filed its income tax return for 1920 with the collector of internal revenue in Boston, on which the Commissioner assessed the tax now in dispute. The taxpayer then petitioned the Board of Tax Appeals to review the assessment, and the Board affirmed the Commissioner. Thereupon the taxpayer filed a petition for review in this court, and the parties stipulated in supposed accordance with section 1225 (d) of title 26 of the United States Code (26 USCA § 1225(d) that we should hear the case. Our jurisdiction depends upon whether the…