Archer-Daniels-Midland Co. v. United States

Johnson, Judge:

The merchandise at issue in this case was invoiced as consisting of “Linseed Oil Foots (Derived from the Alkali Refining of Linseed Oil).” As it was found to contain large percentages of free fatty acids, it was assessed for duty at 20 per centum ad valorem under the provisions of paragraph 1558 as a nonenumerated manufactured article, not specially provided for. An internal revenue tax was also assessed by the collector under the provisions of section 2491 (b) and (c) of the Internal Revenue Code, at 4K cents a pound on the free fatty acids and salts of fatty acids.

The…