Dauphin Deposit Trust Co. v. United States

JOHNSON, District Judge.

This is a suit by the Dauphin Deposit Trust Company to recover $2,251.03 and interest, paid by it under protest for internal revenue stamps which the Collector required it to attach to certificates of participation drawn in a form set forth. The case was submitted to the court on a stipulation of facts.

The question is whether the certificates are taxable as corporate securities under the provisions of the Revenue Act of 1926, tit. 8, § 800 et seq., Schedule A (1), 26 USCA § 901, Schedule A (1), or, more narrowly stated, whether they are known generally as corporate…