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Court Cases Cited
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In 1878, Charles A. Snyder was engaged in the business of the manufacture of tobacco in the city of New Orleans, and became indebted to the United States for internal revenue taxes in the sum of several thousand dollars. These taxes were duly assessed and certified to the collector of internal revenue, who made demand for payment. At the time of the indebtedness and demand for payment Snyder was the owner of certain parcels of real estate located in New Orleans. Snyder later sold the property to the International Cotton-Press Company. Louisiana law required that all liens be recorded. The issue at stake was whether the revenue commissioner could sell the property to collect the debt despite the transfer of ownership. The facts and statutes were largely undisputed, therefore the only question the Court truly addressed was whether the tax system of the United States is subject to the recording laws of the states. The Court declared that Article I Section 8 of the Constitution rendered the question moot. by rendering the question moot, federal law and procedure had been satisfied. The case was remanded back to the lower courts. Full Text: United States v. Snyder, 149 U.S. 210 (1893) |
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