Provost v. United States

The appellants are co-partners engaged in business as stock brokers with membership in the New York Stock Exchange. They brought suit in the Court of Claims to recover, as an illegally exacted tax, the cost of internal revenue stamps affixed by them in the period from 1917 to 1920 to “tickets” which were documentary evidence of transactions commonly known in the stock-brokerage business as the “ loan ” of shares of stock and the return by the borrower to the lender of shares of stock “ borrowed.” The case was tried upon agreed facts embodied in the findings of the court below, and from the…