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U.S. Supreme Court

Universal Battery Co. v. United States, 281 U.S. 580 (1930)

Universal Battery Co. v. United States

Nos. 127, 275, 350, 351, and 352

Argued January 21, 1930

Decided May 26, 1930

281 U.S. 580


1. The construction of the terms "parts" and "accessories" adopted in administrative regulations issued under § 900 of the Revenue Acts of 1918 and 1921 (which imposed a manufacturers' excise tax upon the sale of automobile parts and accessories), whereby articles primarily adapted for use in motor vehicles are to be regarded as parts or accessories of such vehicles, even though there has been some other use of the articles for which they are not so well adapted, is reasonable, and, having been adhered to in the Internal Revenue Bureau for about ten years, should be upheld. P. 281 U. S. 583.

2. Applying that construction to sales of specific articles, it is held that storage batteries, of a type specially suitable for use on automobiles as replacements, and not adapted to any other primary purpose or use, and replacement parts for speedometers and bumpers, were properly regarded as parts or accessories, while storage batteries, of a type alleged to be not primarily adapted for use on automobiles, and gascolaters, a device alleged to be sold for general use on various types of internal combustion engines as well as automobiles, could not properly be regarded as parts or accessories unless there are affirmative findings on the issue of primary adaptation. P. 281 U. S. 584.

66 Ct.Cls. 748; 68 id. 366, reversed.

67 Ct.Cls. 275; id. 287; id. 711, affirmed.

Certiorari, 280 U.S. 539, 546, 547 to review judgments of the Court of Claims sustaining excise taxes under § 900

Page 281 U. S. 581

of the Revenue Acts of 191 and 1921, upon the sales of articles classed as "parts or accessories" for motor vehicles.

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