What follows is an opinion from a United States Court of Appeals. Your task is to identify what party initiated the appeal. For cases with cross appeals or multiple docket numbers, if the opinion does not explicitly indicate which appeal was filed first, assumes that the first litigant listed as the "appellant" or "petitioner" was the first to file the appeal. In federal habeas corpus petitions, consider the prisoner to be the plaintiff.

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. SHERWOOD SWAN AND COMPANY, Ltd., et al., Respondents.
No. 19627.
United States Court of Appeals Ninth Circuit.
Nov. 8, 1965.
Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Edward L. Rogers, Attys., Dept, of Justice, Washington, D. C., for petitioner.
James F. Crafts, Jr., Orrick, Dahlquist, Herrington & Sutcliffe, San Francisco, Cal., for respondent.
Before HAMLEY, HAMLIN and DUNIWAY, Circuit Judges.
HAMLEY and DUNIWAY,
Circuit Judges:
The decision of The Tax Court is affirmed for the reasons stated by that court in its opinion reported at 42 T.C. 299.

Question: What party initiated the appeal?
A. Original plaintiff
B. Original defendant
C. Federal agency representing plaintiff
D. Federal agency representing defendant
E. Intervenor
F. Not applicable
G. Not ascertained
Answer: