By ig sigs agony 5Bs iGiuced in the said eax per cent of the tex and interest peyment represent additional texes esessecd on sales per by the texzpeyer az agent of Js Ws -& id, 8, Drowning Company, and not in : ony other capacity, which ar ma arias were imported by the d, B, & My Sy, Bre mine VOMDEaTIY. the Later corporation meade returns and igre the taxes. there~ 05 in the sum of $23,373465, based on the fair market price thereof. end. the the contention whole additicns Legs ily & &, 8, to thereof, the srice made that this additional the tex should and Upon which computed be based, and that neither this Srowning " Compe eny wer liable for Coitionsnl on the saie not taxabie Browhlng upon tax erbitrary and texpeyer eny part might nor d. My of said tax. “Approximately interest inc nded in “(a) is is based ninety-six per sent of the payment represents the tax and taxes assessed om of firgermse which the taxpayer co anteends under the i@w to it or to dg. Me & Ma So Company ‘that all for the following of said sales were made were ressonet Browning ellen oa & cor sont Son a duly licensed to trensect business eouri, end having an office aa by ie tae State of Uteh, im the State or igs &t L132 Soruce Street, in ot. Louis, and thet seid e¢enrporation ws not the manufacturer, mor the oroducer, nor the importer of eny of the firearms which were the subject of gaid SELES» i#st Amer toe mentioned, on dune ; Paxpayer, sold Na a 4: | i for a S&S, Srowiing date of the an edequete aerme were within is, i932, and delivered Company, prior ana on to Revenue Act of L932, in good end valueble eons sic eration, hich hes been paid, end thence hitherto the ve fat hes hed no right, title nor inter est da seid firecras nor in any thereof, nox in any of th of firesrus with respect to which said tax’ ws — except only es to ite comalssions or factor, in the proceeds of any such "(¢) That the texpsyer, to the extent thet it hes participated in saic gales, or in eny thereof, did s solely es the agent or faeter for the said ds UW, & Me Browning Company, ena not in its oen right or in its own “(d} dune S6lie, behsif, Thet 16, full 1932, details including resolutions of the iu respect copies boards of to 6616 all salecon the bilis of directors the selling end purchasing corporction, aireedy been subaitteé to the Volleetor of of both et¢., have “pd to the Comaissioucr of Internal Revenue. See Protest and Opjecticns to Assesemente of Bxcise Tax, indenttifying Synvole M, T. ~ We Pe £4, filed with the Collector of internal Aeverme at St. Louis, Mis souri, Lecember 16, 3935, sna sbatenent 1936 by : revay sFOnCe meiled to the wece ssid a pert of collector the claim vanuary for 13, Bs