Walter G. Moyle, Washington, Page D. Esquire C, #2 July 19, 1940 Final file contains the schedule of comparative prices which we furnished Mr. Hoyt, and computations of the basis of our offer in compromise and a statement of the receipts from sales which i were due you to will price find no difficulty By way of brief In 1962 collaborating hope Baxter, we attempted to which had been imported the United States might ing Company Section by the G10 before of importer, outline, file locating the situation with effective imposed etc, Hach in a is Scholefield, date sales We adopted the arms the being anything labeled, you want, this: Wells: and work out a plan by which by Browning Arms Company be transferred to the J. the which increases, the firearms for sale within M. & BM. S. Brown- of the Revenue Act of tax on the of firearms sele plan of conveying were sold to all 1982, of the arms to J. 4M. & M. S. Browning Company. That was done, and the entire purchase price paid immediately by credit upon a claim Which the parent company held against the Arms Company for money ient. The stock of the arms in the bonded warehouse at St. Louis was transferred into the name of the parent company and thereafter 1t made and paid for all subsequent importations. A detailed inventory was made of which the parent, and thereafter all sales were carefully allocated between the arms which were sold in bulk, which we called the inventory, and subsequent importations. made The agency contract between the two corporations was shortly after the transfer of the arms and expressed the oral agreement made before the effective date of the act. (See the minutes in the protest). I believe we can safely say that the agreements have been strictly lived Shortly after the transfer, J. company, in making an excise tax report, done, stating the details in the form of they are stated in the protest. The up to. MW. & M. &. Browning reported what had been an affidavit much as transaction was approved by the Commissioner, as will appear from the Deputy's letter of 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 a 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