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POSADOS v. WARNER, B. & CO.

Nos. 251 and 252.

279 U.S. 340 (1929)

POSADOS, COLLECTOR OF INTERNAL REVENUE, v. WARNER, BARNES & COMPANY, LTD. POSADOS, COLLECTOR OF INTERNAL REVENUE, v. MENZI.

Supreme Court of United States.

Decided April 22, 1929.

Attorney(s) appearing for the Case

Mr. Wm. Cattron Rigby, Judge Advocate, with whom Messrs. Edward A. Kreger, Judge Advocate General, U.S.A., and Delfin Jaranilla, Attorney General of the Philippine Islands, were on the brief, for petitioner.

Mr. Martin Taylor presented the oral argument for respondents, and Messrs. Clyde Alton DeWitt and Eugene Arthur Perkins submitted a brief in behalf of respondent Warner, Barnes & Co., Ltd.

MR. JUSTICE BUTLER delivered the opinion of the Court.

No. 251.

Respondent sued petitioner in the court of first instance of Manila to recover a tax alleged to have been illegally imposed on a stock dividend. The tax was levied under Act 2833 of the Philippine Islands, approved March 7, 1919, as amended by Act 2926, March 26, 1920. The provision here involved is substantially like that in § 2(a) of the Revenue Act of 1916 for the United States, which...

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