Walter G. Washington, Page #2 which we Moyle, D. Esquire C, July Final file contains the schedule of furnished ir. Hoyt, and computations our offer in compromise sales which were due to i hope you will find no and a statement of the price increases, Each difficulty in locating Dy way of In 1952 collaborating brief outline, the with 19, 1940 comparative prices of the basis of receipts from file being labeled, anything you want, situation is Scholefield, this: Wells and Baxter, we attempted to work out a plan by which the firearms which had been imported by Browning Arms Company for sale within the United States might be transferred to the J. BM. & M. &. Browne ing Company before the effective date of the Revenue Act of LOSZ, section by the the 610 of which importer, arms to Jd. i. imposed etc, We & M. a sales adopted &. Browning tax the on plan the of Company. sale of conveying That was firearms all of done, and Louis the entire purchase price paid immediatelyby credit upon a claim which the parent company held against the Arms Company for noney ient. The was transferred after it made inventory thereafter woich were sequent made oral the the they the was of the arms in into the the bonded name warehouse of the at parent subsequent company and importations. which were sold to and paid for all made of the arms the St. there~ A detailed parent, and all sales were carefully allocated between the arms sold in bulk, which we called the inventory, and sub-~ importations. The agency contract between the two corporations was shortly after the transfer of the arms and expressed the agreement made minutes in agreements company, Gone, stock the effective date of we up safely Shortly after the transfer, J. in making an excise tax report, stating are before the protest). I believe have been strictly lived stated the Commissioner, in details the as in the protest, will appear can to. form of transaction the say (See that Me. & M. 8. Browning reported what had been The from the act. an affidavit Deputy's was much eas approved letter of by July £4, 1925, in the sundry correspondence file, but in 1935 the case was re-opened, investigations made, and notice given of the intent to levy @ tax upon all these sales. The protest was then filed. The tax however, was levied and was paid under protest, and a claim for the refund was filed. This claim was rejected, It was prepared by one who was supposed to be an expert, but wnfortun~ ately it contained no statement that the taxes had not been passed