Garod Radio Corp. v. United States

DISSENTING OPINION

Donlon, Judge:

There appears to be a continuing difference of opinion in this division as to the jurisdiction of the court in a protest proceeding, such as this, which challenges the validity of the appraisement on which the collector relied in making his liquidation. Earlier, the difference of opinion was expressed in J. V. Whitaker, etc. v. United States, 43 Cust. Ct. 437, Abstract 63621.

A protest may, of course, meet the requirements of section 514, even though it is not drawn with technical precision, provided it clearly shows the grounds of the protest. Here, we have a…