Helvering v. Insular Sugar Refining Corp.

This is a petition by the Commissioner of Internal Revenue to have us review and reverse a decision of the Processing Tax Board of Review, determining that respondent is entitled to a refund of the sugar processing tax paid by it in the period September 12, 1934, to January 6, 1936, to the extent of $230,511.31. The case is this:

Respondent, which we shall call “claimant”, was at the time in question a Philippine corporation, with its office and refinery in the Islands. It purchased there its raw sugar, processed it, and sold its product as to about fifteen per cent (15%) locally and the…