Lawyers' Mortgage Co. v. Anderson

MANTON, Circuit Judge.

Appellee recovered moneys paid under protest as stamp taxes alleged to be due upon the issuance by it, during the period from February 16, 1926, to February 1, 1930, of guaranteed first mortgage certificates without placing thereon documentary stamps. Appellant made the assessment pursuant to section 800, Schedule A (1), title 8, of the Revenue Acts of 1924 and 1926 (26 U. S. C. § 901, 26 USCA § 901, Schedule A (1) and note), which provided for a stamp tax “On all bonds, debentures, or certificates of indebtedness issued by any corporation ['person’ in the 1924 act], and…