United States v. Leslie Salt Company

HEALY, Circuit Judge.

This is a suit to recover taxes exacted under 26 U.S.C.A. §§ 1800 and 1801.

Section 1801 in material part provides : “Corporate securities. On all bonds, debentures, or certificates of indebtedness issued by any corporation, and all instruments, however termed, issued by any corporation with interest coupons or in registered form, known generally as corporate securities, on each $100 of face value or fraction thereof, 11 cents. * * *”

The transactions in question were two loans negotiated by the taxpayer in 1949 with insurance companies in amounts of $1,000,000 and…