Show SU IP TAX eRI Call StoL Stock Not 11 as Washington March At Attorney t torney torne General James E nod Boyd today rendered In an opinion to the secretary of at atthe the treasury which Is approved by the attorney general on the question as to the taxabIlity of transactions known ax as ascal cal call loan Mr Boyd holds that tn In order CD b bring these transactions transaction withIn the tho provIsions ot of the paragraph of schedule A t the tho war revenue act levy ley levying Ing a tx tax upon mortgages and I edges n Os securIty for the payment ot of mono money the prOperty whether wether real or In he mortgage or pledge must be described therein and must also be made o as securIty lor or orthe the payment ot of I a de and certain sum ot of money loaned at the Ibe time or previously duo and owing or forborne to be being payable that there I lx no document paper or r Instrument executed made or Issued In the trans transactions actions described t as cal call loans whIch com comes within the and that such transactions are nb nt and there therefore tore 1 mortgages pledges ot of property to secure the pa pay nent of money The Tho second point treated ot of In the opinion II Is as to the liability ot of such uch transaction to stamp tx tax under the tho first fr Paragraph of Schedule A ot of the revenue ac act as al a delivery or of stock to secure the future of at mone money Tho attorney general decides tian than an analysis of the tho porton portion of the said paragraph Jh pertaining to this mat matter tr ter leads lendl hl hin to the conclusion that its constructing should Lo be JI as olof On ni all sates made by any delivery to lecure secure the future payment ament of at money on each tach hundred dollars of taco face value alte two cents Tle The resul result Is that a mer mere hypothecation ton tion o of shares ot of stock UI as collateral se ao turUy or t U n basis of credit unac by agreements or o of sale or dr stIpulations which flake such for the tho payment of at n a definite and certin certain suit of money mone loaned at ho time or previously due and or forborne to he be paid being payable ts is tot not a taxable transaction under th the provisions ot of the war revenUe Ret In the opinion the general propositIon I II laid down that the taxes requIred lI by A ot of the act referred to are paid by the u use ot of Stumps and that thU In order to co et the saint ame some document In Instrument or paper written or printed luch al as 11 is Contemplated b by the statute to which the stamp Cn can be must mut be made signed limed or Issued ti tiLi L Li l |