Legal Opinion

Insular Sugar Refining Corp. v. Commissioner

United States Tax Court

Decided May 31, 1944No. Docket No. 108871Published

Petitioner, a Philippine Islands corporation engaged in refining sugar, purchased in the United States the cotton bags in which its sugar was packed and sold. The manufacturer exported the bags to petitioner and added the cotton processing tax to the price charged. Petitioner later received reimbursement of the burden of the tax, the vendor having obtained refunds from the Government.

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Petitioner, a Philippine Islands corporation engaged in refining sugar, purchased in the United States the cotton bags in which its sugar was packed and sold. The manufacturer exported the bags to petitioner and added the cotton processing tax to the price charged. Petitioner later received reimbursement of the burden of the tax, the vendor having obtained refunds from the Government. Held, that the reimbursement is not exempt from the unjust enrichment tax by reason of the exportation of the bags; that petitioner is liable for unjust enrichment tax based upon the full amount of the…

1Opinion of the Court

Insular Sugar Refining Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Insular Sugar Refining Corp. v. Commissioner

Docket No. 108871

United States Tax Court

3 T.C. 922; 1944 U.S. Tax Ct. LEXIS 113;

May 31, 1944, Promulgated

Decision will be entered for respondent.

Petitioner, a Philippine Islands corporation engaged in refining sugar, purchased in the United States the cotton bags in which its sugar was packed and sold. The manufacturer exported the bags to petitioner and added the cotton processing tax to the price charged. Petitioner later received reimbursement of the…

2Cases cited1 opinion

  1. Insular Sugar Refining Corp. v. CommissionerUnited States Tax Court · 1944

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