Serrallés v. Sancho Bonet

Pedro Juan Serrallés y Galiano bought in the United States a vessel which he described thus: “A yacht 85 feet long', of 5% draught, 16 feet wide, 200 H.P., with two motors, NY. Yacht Engine Co. (builders), which was duly registered and licensed in the Port of New York, to be used not only in waters adjacent to Puerto Rico, but also in trips between states and also between other nations . . .

The Treasurer of Puerto Rico demanded from Serrallés the payment of an excise tax under subdivision 8, section 16 of the Internal Revenue Law of Puerto Rico, enacted in 1931 (Session Laws, p. 504), as…