Richard Nelson Co. v. United States

Kao, Judge:

The merchandise involved in this case, described on the invoices as “Black Sheathing Hoofing Felt,” was assessed with duty at 20 per centum ad valorem under item 355.05, Tariff Schedules of the United States, which item includes nonwoven fabrics, felts, and bonded fabrics, whether or not coated or filled. It is claimed to be dutiable at 5 per centum ad valorem under item 251.05, which covers building papers and building paper-felts, whether or not coated or saturated.

The pertinent provisions of the tariff schedules are as follows:

Schedule 3 - Part 4 - Subpart C

Subpart C headnotes:

2.…