United States v. Wanamaker

DISSENTING OPINION

I concur in the construction placed upon paragraph 1310 of the Tariff Act of 1922 and in the conclusion reached by the majority of the court as to the issues involved in protest 397196-G. I am unable to agree, however, to that part of the decision holding that protest 327015-G was “insufficient to entitle the importer to the relief granted by the court below.”

It has been frequently held that protests should be liberally, not strictly, construed; that the object of a protest was to call the collector’s attention to the nature of the objection made to his decision, so that the…