Treat v. Tolman
Court of Appeals for the Second Circuit
In Error to the Circuit Court of the United States for the Southern District of New York. This is an appeal from a judgment entered in favor of the plaintiff in a cause tried in the circuit court for the Southern district of New York (106 Fed. 679) upon an agreed state of facts, the substantial portions of which are as follows: The defendant is the collector of internal revenue of the United States in this district.
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In Error to the Circuit Court of the United States for the Southern District of New York. This is an appeal from a judgment entered in favor of the plaintiff in a cause tried in the circuit court for the Southern district of New York (106 Fed. 679) upon an agreed state of facts, the substantial portions of which are as follows: The defendant is the collector of internal revenue of the United States in this district. The plaintiff made loans of divers sums of money to various persons, from whom he received 1,025 instruments or memoranda in writing, commonly known as “judgment notes,” of which…
1Opinion of the CourtTownsend, District Judge
(after stating the facts). The legislative intent, as disclosed by the special provisions of said schedule, appears to have been to tax those instruments by which one individual authorizes another to act on his behalf, either at meetings of corporations, or in the transaction of certain classes of business relating to real estate or corporate securities, or claims against the United States not enumerated in > said proviso. The general clause, “or to perform any or all other acts not hereinabove specified,” should, therefore, be interpreted, under the doctrine of noscitur a sociis, to refer to…
2Cases cited4 opinions
- Hunt v. Rousmanier's AdministratorsSupreme Court of the United States · 1823
- Boyd v. HoodSupreme Court of Pennsylvania · 1868
- Smith v. WatersIndiana Supreme Court · 1865
- Davis v. OstranderNew York Supreme Court · 1799
3Cited by5 opinions
- Yee Chong Lung & Co. v. United StatesCourt of Customs and Patent Appeals · 1922
- In re the Estate of KatzNew York Surrogate's Court · 1934
- Rico Products Co. v. United StatesUnited States Customs Court · 1961
- In re HawleyDistrict Court, S.D. New York · 1915
- Government Personnel Automobile Ass'n v. United StatesCourt of Appeals for the Fifth Circuit · 1941