PORTO RICO TAX APPEALS

Nos. 1904, 1908, 1923, 1924, 1940-1949, and 1951-1978.

16 F.2d 545 (1926)

PORTO RICO TAX APPEALS. INSULAR MOTOR CORPORATION v. GALLARDO, Treasurer, and forty-two other cases.

Circuit Court of Appeals, First Circuit.

On Rehearing, January 7, 1927.


Attorney(s) appearing for the Case

Francis G. Caffey, of New York City (George W. Study, of New York City, and Cay. Coll y Cuchi and Gustavo Cruzado Silva, both of San Juan, Porto Rico, on the brief), for appellants Insular Motor Corporation and others.

Carroll G. Walter, of New York City (Vicente Zayas Pizarro, of Ponce, Porto Rico, on the brief), for appellants Forteza and others.

Carroll G. Walter, of New York City (J. Henri Brown, of San Juan, Porto Rico, on the brief), for appellants Valdez and others.

Nelson Gammans, of New York City (Benicio Sanchez Castano, of San Juan, Porto Rico, on the brief), for complainant appellants.

Russell H. Brennan, of Washington, D. C., and J. A. Lopez Acosta, Asst. Atty. Gen. (George C. Butte, Atty. Gen., on the brief), for appellee.

Before BINGHAM, JOHNSON, and ANDERSON, Circuit Judges.


JOHNSON, Circuit Judge.

All these cases raise the question whether the District Court of the United States for Porto Rico had equitable jurisdiction, because the complainants did not have a plain, adequate, and complete remedy at law.

July 28, 1923, the Porto Rican Legislature enacted a law whose title is "The Excise Tax Law of Porto Rico." Under title 2, part 1, § 20, the act (No. 68) provided for the levying and collection, at one time only, of an internal...

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