Brown's "Shamrock" Linens, Ltd. v. Bowers

SWAN, Circuit Judge.

The plaintiff is a corporation organized under the laws of Great Britain, and during the year 1918 it was engaged in the business of importing and selling in the United States linens and other textiles. Being a foreign corporation, the assessment of its war profits and excess profits tax was required, by section 327(b) of the Revenue Act .of 1918, to be computed by the Commissioner in accordance with section 328 (40 Stat. 1093). That section reads in part as follows:

“Sec. 328. (a) In the cases specified in section 327 the tax shall be the amount which bears the same ratio…