Terminal tax exemption for corporate self-use imports upheld where building materials were brought in for a company's own mill construction.

Goods imported within municipal limits for a company's own use in constructing its mill fell within the exemption from terminal tax for goods brought in for bona fide personal use and not for sale, provided the quantity was reasonable. The court treated "personal use" as equivalent to "private use" when applied to a corporation, because a company may be a "person" for tax purposes and the real distinction in the rule was between imports for sale and imports for the importer's own use. On that basis, the company was entitled to the exemption and the appeal failed.

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Issues: Whether a company importing building materials for use in constructing its own mill was entitled to exemption from terminal tax under the rule exempting goods for bona fide personal use and not for sale.

Analysis: The terminal tax was levied on goods imported within municipal limits, but the rules exempted goods brought in for bona fide personal use and not for sale, provided the quantity was reasonable. The goods in question were imported by the company for its own use in building its mill and not for sale. The expression "personal use" was treated as equivalent to "private use" in the case of a corporation, since a corporation can be a person for the purposes of the tax and the real distinction in the rule was between goods imported for sale and goods imported for the importer's own use.

Conclusion: The company was entitled to the exemption, and the appeal failed.

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