Mutual Life Insurance v. United States

Plaintiff sues to recover the amount which it had to pay for stamps which the Bureau of Internal Revenue ruled should have been affixed to certain deeds received by it from mortgagors who had defaulted in the payment of the mortgage debt. Forty-four deeds are involved. The deeds were ' given in lieu of foreclosure proceedings. They were all executed between February 2, 1938 and December 31, 1941.

Section 3480 of the Internal Revenue Code levies a tax “for and in respect of” various documents set out in subsequent sections, among which are “conveyances”, described in section 3482. Among the…