BRAUCHER, J.
The plaintiff taxpayer, trustee of a Massachusetts trust with transferable shares, appeals from a decision of the Appellate Tax Board. Neither party requested the board to make findings of fact and a report thereof. The defendant commission argues that the board's decision must have turned on the factual question whether the receipts in dispute were "shown by the books" of the trust before 1971. G.L.c. 62, § 1 (f), as appearing in St. 1971, c. 555...
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