Lederer v. Fidelity Trust Co., 267 U.S. 17 (1925)

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Lederer v. Fidelity Trust Company


No. 184


Argued January 15, 16, 1925
Decided January 26, 1925
267 U.S. 17

CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE THIRD CIRCUIT

Syllabus

1. Railroad equipment certificates issued by a trust company as security for money advanced by a syndicate to purchase equipment leased by the trust company to a railroad under contract for periodical payments, as rentals, and ultimate acquisition of title by the latter, and which are payable with interest to bearer or registered holder from the rentals thus to be paid by the railroad, held subject to stamp tax under Title XI, § 1100 and schedule A(1) of the Act of February 24, 1919, c. 18, as in the category of "instruments . . . issued by any corporation . . . known generally as corporate securities." P. 20.

28 F. 1009 reversed.

Certiorari to a judgment of the circuit court of appeals which reversed a judgment of the district court in favor of the petitioner in an action brought by the respondent to recover the amount of a stamp tax paid under protest.