property, where the orders are sent outside the State for approval or rejection, and the orders are filled by shipment or delivery from a point outside the State. 2 Howmet expected that the subpoenas would elicit information from the department showing that the commissioner has no governing standard concerning the applicability of Pub. L. No. 86-272, and that, therefore, any prosecution for a failure to file Massachusetts corporate excise tax returns would, on its face, violate due process on the ground of vagueness. 3 Section 1291 of the Judicial Code allows appeal to the Federal Courts of Appeal “from all final decisions of the district courts of the United States.” 4 Prior to this opinion, we have not been asked to apply the Perlman exception. Cf. Cronin v. Strayer, supra at 530 n.7 (<HOLDING>); Borman v. Borman, supra at 783 (“Perlman [is]
holding that nonparty witnesses may not appeal discovery orders but noting in dictum that perlman rule is most common exception to the general rule that pretrial disclosure orders are not appealable holding that orders remanding an action to a federal agency are generally not considered final appealable orders holding that remand orders are also appealable orders under 28 usc  1291 recognizing perlman rule holding that orders overruling claims of privilege and requiring disclosure are immediately appealable as collateral orders