Hoyt v. United States

55 Cust. Ct. 10, 1965 Cust. Ct. LEXIS 2388
CourtUnited States Customs Court
DecidedJune 24, 1965
DocketC.D. 2548
StatusPublished

This text of 55 Cust. Ct. 10 (Hoyt v. United States) is published on Counsel Stack Legal Research, covering United States Customs Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoyt v. United States, 55 Cust. Ct. 10, 1965 Cust. Ct. LEXIS 2388 (cusc 1965).

Opinion

Rao, Judge:

This is a protest against the collector’s assessment of duty at the rate of 22y2 per centum ad valorem upon an importation of merchandise invoiced as mauls with axe eye. It is not clear from the record or from the official papers whether this action was predicated upon the provision for hammers in paragraph 396 of the Tariff Act of 1930, as modified by the Torquay Protocol to the General Agreement on Tariffs and Trade, 86 Treas. Dec. 121, T.D. 52739, supplemented by Presidential proclamation, 86 Treas. Dec. 337, T.D. 52820, or upon the provision for all other cutting tools in said paragraph 396, as modified by the Annecy Protocol to the General Agreement on Tariffs and Trade, 84 Treas. Dec. 403, T.D. 52373, supplemented by Presidential proclamation, 85 Treas. Dec. 116, T.D. 52462.

It appears, however, that counsel for the Government, although admitting that items like those in issue have been classified as cutting tools, takes the position, for the purposes of the present litigation, that the collector considered the subject articles to be hammers.

In any event, it is the contention of plaintiffs that the instant mauls are neither hammers nor cutting tools, within the purview of said paragraph 396, as modified by the respective trade agreements, supra, but that they are, in fact, or in contemplation of law, wedges, which are provided for in paragraph 326 of said act, as modified by said Torquay protocol, at the rate of fj/jg of 1 cent per pound.

The provisions in question are as follows:

Paragraph 396 of the Tariff Act of 1930, as modified by the Torquay protocol, supra—

Pipe tools, wrenches, spanners, screw drivers, bit braces, vises, and hammers; all the foregoing, if hand tools not provided for in paragraph 352, Tariff Act of 1930, and parts thereof, wholly or in chief value of metal, not specially provided for_ 22%% ad val.

Paragraph 396 of the Tariff Act of 1930, as modified by the Annecy protocol, supra—

Drills (including breast drills), hits, gimlets, gimlet-bits, countersinks, planes, chisels, gouges, and other cutting tools; all the foregoing, if hand tools not provided for in paragraph 352, Tariff Act of 1930, and parts thereof, wholly or in chief value of metal, not specially provided for_ 22%% ad val.

Paragraph 326 of said act, as modified by said Torquay protocol—

Blacksmiths’ hammers, tongs, and sledges, track tools, wedges, and crowbars, of iron or steel_per lb.

[12]*12Evidence as to the character, composition, and use of the instant mauls was given by Mr. Edward W. Strohecker, one of the owners of plaintiff, Robert O. Bossinger & Co., who testified on behalf of plaintiffs. This witness also produced for admission into evidence a sample of the imported articles representative in all respects, except as to weight (plaintiffs’ exhibit 1), an axe (plaintiffs’ exhibit 2), and a wedge (plaintiffs’ exhibit 3).

The sole evidence for the defendant consisted of two pages of a catalog (exhibit A) of the Klein-Logan Co., a manufacturer of various kinds of tools.

According to the witness, his company is primarily engaged in the heavy hardware business as importer, wholesale distributor, and representative. It has been importing the articles at bar for about 6 years, but has handled a comparable domestic item produced by the Klein-Logan Co. for about 25 years. He gave the following description of the manner in which this article is used:

It may be used in two ways. They can either be initially propelled into a piece of material by holding it in your left or right hand, whichever you are, and hitting it on the head with another instrument such a [sic] sledge hammer or something of that nature. And in this manner it may be used identically as that of a common, what we commonly refer to as a splitting wedge. Or a handle may be inserted into the eye of the tool and then motivated by your own force the tool may be projected into the material you are working with.

In the opinion of Mr. Strohecker, the subject mauls are distinguishable from axes in that they are of different composition and construction. The former are composed of a substantially greater amount of steel and differ in taper from the bit to the head. Articles like exhibit 1 are so constructed that propulsion force exerted against them will cause a splitting of fibers rather than a breaking or cutting. An axe is of much lighter material, is made of a higher quality product, and is ground and tempered five times. It has a long taper of approximately 1 to 3 inches and can cut as well as split. He likened exhibit 1 to the wedge in evidence as plaintiffs’ exhibit 3 in that it is a heavier item than an axe, is made of a substantially greater amount of material, tempered but not ground, and performs much the same basic function.

The witness was of opinion that splitting and cutting are distinguishable operations in that the former causes a separation of wood along the natural grain, the latter has the capacity to separate either with or against the grain. He did not believe that plaintiffs’ exhibit 1 would be useful for cutting wood against the grain.

In the respect that Webster’s New International Dictionary, 1933 edition, defines a wedge as an item of metal tapering to a thin edge, used in splitting wood, Mr. Strohecker was in general agreement with it, and he stated that exhibit 1 could be used in this manner. [13]*13When, however, a handle is inserted, the flat surface of the item could be used as a hammer, although it is not particularly suitable for that purpose as it is not properly balanced for such use. Moreover, the article is imported without a handle.

On cross-examination, this witness stated that a maul, such as plaintiffs’ exhibit 1, has a hole in it for the insertion of a handle. Although the hole is designated as an axe-eye hole because it is approximately 1% to 2 inches in length, approximately three-quarters of an inch in width, and tapers from both extremes to the center, the handle used with exhibit 1 would not work on any other tool. The designation “axe-eye hole” is a term employed in the handle and forging industries to indicate any elongated eye, not necessarily only the hole in the head of an axe.

The witness identified item No. 122 on pages 10 and 11 of the catalog of the Klein-Logan Co. as a woodchopper’s maul with an axe eye, similar to plaintiffs’ exhibit 1. He further testified that plaintiffs’ exhibit 1 could be used with or without a handle; that he did not believe that the handle adds anything to the quality of the product. However, he has sold such articles with handles.

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Related

Meyer v. United States
6 Ct. Cust. 181 (Customs and Patent Appeals, 1915)

Cite This Page — Counsel Stack

Bluebook (online)
55 Cust. Ct. 10, 1965 Cust. Ct. LEXIS 2388, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hoyt-v-united-states-cusc-1965.