Hermanos v. Tax Court of Puerto Rico

Does Puerto Eico have the power to impose a property tax on imported merchandise which on the assessment date was on a foreign ship in the San Juan harbor and had not yet been released to the importer by the customs authorities ?

Ballester Hermanos imported into Puerto Rico from Argentina merchandise valued at $118,250 which arrived in the port of San Juan on January 13, 1943 in an Argentine ship. The Treasurer demanded payment of the property tax of $3,382.12 for the fiscal year 1943-44 on this merchandise. The taxpayer contested this claim in the Tax Court, where the parties stipulated that…