Leslie Salt Co. v. United States

GOODMAN, District Judge.

26 U.S.C. § 18011 imposes a tax of 11 cents on each $100 of face value, inter alia, upon all “debentures” issued by any corporation.

Plaintiff corporation owed large sums of money to -certain banks. In order to fund these loans and to obtain needed working -capital, it borrowed $1,000,000 from Pacific Mutual Life Insurance Company and $3,000,000 from Mutual Life Insurance Company of New York. It executed promissory notes for $1,000,000 and $3,000,000 respectively to the two insurance companies. Simultaneously it executed agreements with the insurance -companies, by…