United States v. Leslie Salt Co.

On February 1, 1949, Leslie Salt Company, being in need of funds to meet maturing bank loans and for work ing capital, borrowed $3,000,000 from the Mutual Life Insurance Company of New York and $1,000,000 from the Pacific Mutual Life Insurance Company. As evidence of the indebtedness Leslie Salt delivered to each insurance company its “3 1 /4% Sinking Fund Promissory Note Due February 1, 1964” in these amounts. The question presented is whether these instruments are subject to the documentary stamp taxes laid on “all bonds, debentures, or certificates of indebtedness issued by any corporation…