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Webre Steib Co., Ltd. v. Commissioner, 324 U.S. 164 (1945)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Webre Steib Co., Ltd. v. Commissioner, 324 U.S. 164 (1945)
Webre Steib Co., Ltd. v. Commissioner of Internal Revenue No. 148 Argued December 13, 1944 Decided February 12, 1945 324 U.S. 164
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE FIFTH CIRCUIT
Syllabus
1. In a proceeding under Title VII of the Revenue Act of 1936 for a refund of processing taxes paid under the Agricultural Adjustment Act of 1933, the presumption from margin evidence that the claimant bore the burden of the tax requires, in the absence of opposing evidence, a refund pro tanto. P. 169.
2. The presumption arising from margin evidence favorable to the claimant places upon the Commissioner the burden of going forward with evidence sufficient to support a finding that the claimant did not bear the burden of the tax. P. 170.
3. The Commissioner’s evidence in this case was sufficient to support a finding that the claimant had not borne the burden of any part of the tax, and the presumption from the claimant’s margin evidence was thereby rendered inoperative. P. 171.
4. On review of administrative decisions, this Court must determine whether there is evidence legally sufficient for administrative action, but may not weigh it. Dobson v. Commissioner, 320 U.S. 489. P. 173.
5. Although the Commissioner’s rebuttal evidence rendered the presumption inoperative, the record -- the margin evidence being still in the case for whatever it might be worth apart from the presumption -- is not devoid of rational support for a finding that the claimant absorbed some of the tax, and the cause must be remanded to the Tax Court for a weighing of the evidence, including such further evidence as that court may properly admit. P. 174.
6. Evidence as to margins in a period later than the base period, though irrelevant to the presumption created by § 907(a), was admissible for whatever probative value it might have independently. P. 175.
140 F.2d 768 modified.
Certiorari, 323 U.S. 686, to review a judgment which, reversing a decision of the Processing Tax Board of Review, held that a claim for refund of processing taxes should have been disallowed in its entirety.
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Chicago: U.S. Supreme Court, "Syllabus," Webre Steib Co., Ltd. v. Commissioner, 324 U.S. 164 (1945) in 324 U.S. 164 324 U.S. 165. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=WYY79TJ8L1M9VB8.
MLA: U.S. Supreme Court. "Syllabus." Webre Steib Co., Ltd. v. Commissioner, 324 U.S. 164 (1945), in 324 U.S. 164, page 324 U.S. 165. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=WYY79TJ8L1M9VB8.
Harvard: U.S. Supreme Court, 'Syllabus' in Webre Steib Co., Ltd. v. Commissioner, 324 U.S. 164 (1945). cited in 1945, 324 U.S. 164, pp.324 U.S. 165. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=WYY79TJ8L1M9VB8.
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