opinion: RUSSELL & CO. v. SANCHO.
  No. 3236.
  Circuit Court of Appeals, First Circuit.
  Nov. 9, 1937.
  George M. Wolfson, of New York City (Francis E. Neagle and Rounds, Dilling-ham, Mead & Neagle, all of New York City, on the brief), for appellant.
  William C. Rigby, of Washington, D. C. (B. Fernandez Garcia, Atty. Gen., of Puer-to Rico, and Nathan R. Margold, Sol. for Dept, of Interior, of Washington, D. C., on the brief), for appellee.
  Before BINGHAM, WILSON, and MORTON, Circuit Judges.
  PER CURIAM.
  This court is unable to say that the Supreme Court of Puerto Rico was clearly wrong in ruling and holding that the machine described in plaintiff’s complaint was a tractor and taxable as such under -the provisions of section 16, par. 8, of the Internal Revenue Law of Puerto Rico 1925, No. 85, as amended by Act No. 83, § 16, par. 8, of 1931.
  In this situation the plaintiff cannot recover the additional tax which it paid under protest, and the judgment of the court below will be affirmed.
  The judgment of the Supreme Court of Puerto Rico is affirmed, with costs to the appellee in this court.
instruction: What follows is an opinion from a United States Court of Appeals.
  Intervenors who participated as parties at the courts of appeals should be counted as either appellants or respondents when it can be determined whose position they supported. For example, if there were two plaintiffs who lost in district court, appealed, and were joined by four intervenors who also asked the court of appeals to reverse the district court, the number of appellants should be coded as six.
  When coding the detailed nature of participants, use your personal knowledge about the participants, if you are completely confident of the accuracy of your knowledge, even if the specific information is not in the opinion. For example, if "IBM" is listed as the appellant it could be classified as "clearly national or international in scope" even if the opinion did not indicate the scope of the business. 
  
  Your task concerns the first listed appellant. The nature of this litigant falls into the category "private business (including criminal enterprises)", specifically "unclear". Your task is to determine what subcategory of business best describes this litigant.
choices: auto industry chemical industry drug industry food industry oil & gas industry clothing & textile industry electronic industry alcohol and tobacco industry other unclear