BRAUCHER, J.
This is an appeal by a taxpayer, the trustee of a Massachusetts business trust, from a decision of the Appellate Tax Board. G.L.c. 58A, § 13. Pursuant to G.L.c. 62, § 1 (e), as amended through St. 1963, c. 496, he had filed an agreement to pay taxes imposed by G.L.c. 62, §§ 1 (d) and 5. Thereafter, in 1966, he sold real estate
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