Puerto Rico Auto Corp. v. Tax Court of Puerto Rico

The juridical facts on which our decision in the instant case is based are the following: The Puerto Rico Auto Corporation was, during the years in which the tax in litigation was imposed, the exclusive distributor for the territory of Puerto Rico of certain automobiles manufactured in the *106United States of America. In order to purchase those vehicles, the Puerto Rico Auto Corporation placed its order with the manufacturer and asked the Banco Popular de Puerto Rico to open a credit account in the city of New York for a sum equal to the total purchase price. This credit was used to pay to the…