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SOUTH PORTO RICO SUGAR CO. v. BUSCAGLIA

No. 4091.

154 F.2d 96 (1946)

SOUTH PORTO RICO SUGAR CO. v. BUSCAGLIA, Treasurer of Puerto Rico, et al.

Circuit Court of Appeals, First Circuit.

March 6, 1946.

Attorney(s) appearing for the Case

R. Castro Fernandez, of San Juan, P. R. (James R. Beverley and Jose Lopez Baralt, both of San Juan, P. R., of counsel), for appellants.

I. Henry Kutz, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., Sewall Key and J. Louis Monarch, Sp. Assts. to Atty. Gen., and Fowler Harper and Warner Gardner, Sols., and Irwin W. Silverman, Chief Counsel, Division of Territories and Island Possessions, Department of Labor, all of Washington, D. C., of counsel), for appellees.

William J. Hession, of Boston, Mass., for Central Aguirre Associates, amicus curiae.

Before ALBERT LEE STEPHENS, MAHONEY, and WOODBURY, Circuit Judges.

MAHONEY, Circuit Judge.

This case comes before us on appeal from the Supreme Court of Puerto Rico which reversed a decision of the Tax Court of Puerto Rico in favor of the appellant. It is submitted on an agreed statement of facts which will be briefly summarized.

The appellant, South Porto Rico Sugar Company, hereinafter referred to as the Sugar Company, is a corporation organized under the laws of the State of New Jersey and not registered in nor doing business...

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