CUTTER, J.
Verna R. Fine (the taxpayer), an inhabitant of Natick, filed a Massachusetts income tax return for 1963. She paid a tax of $527.61 on so called "dividends" from Mesabi Trust received by her in 1963. The commission denied her application for abatement. Her appeal was pressed before the Appellate Tax Board (the board) on the ground that no tax was due on income from Mesabi Trust because such "income was derived from real estate located solely in ... Minnesota...
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