Rio Grande Oil Co. v. Welch

HEALY, Circuit Judge.

Appellant sued appellee, Collector of Internal Revenue, to recover an amount assessed as documentary internal revenue stamp taxes of which payment had been made > under protest. From a judgment denying recovery this appeal was taken.

The tax was assessed oti the issue of shares of appellant’s stock in exchange for its outstanding shares. The statute involved is § 800 of the Revenue Act of 1926, c. 27, 44 Stat. 9, 101, 26 U.S.C.A. § 900. So far as material, it imposed a tax “on each original issue, whether on organization or reorganization, of certificates of stock” of…