June 



THE INDIA RUBBER WORLD 



495 



All other rubber goods (including brake linings, buffers, 

 cord, friction tape, gaskets and washers, gasket tub- 

 ing, splicing compound, mats, matting, mold work, 

 roll covering, rubber springs, tubing, valves, cables, 

 " * Lilating compounds, etc.). 



(Fo, 



d wi 

 OUTING DATE CHANGED 



The Outing Committee announces that in order to secure the 

 desired accommodations the annual outing will be held on June 

 24, 1919, instead of June 17, as previously announced. The place 

 will be the Seaview Golf Club, at Absecon, adjoining Atlantic 

 City, New Jersey. 



The Outing Committee is extremely fortunate in securing 

 one of the finest and best equipped clubs in the country for the 

 outing, and in a location that will be central for the entire 

 membership. 



OTHER MANUFACTURERS AGREE TO CRUDE RUBBER CHARGE. 



The following manufacturers have signed the agreement to 

 pay the Rubber Association 3 cents per 100 pounds on all crude 

 rubber purchased by them : 



Cortland Tire & Rubber Co. Pioneer Rubber Mills. 



Dreyfus Co., L. A. Poison Rubber Co., The. 



Luratex Co., The. Schacht Rubber Manufacturing Co. 



Eureka Rubber Manufacturing Co., Zee-Zee Rubber Co. 



OVERLAND FREIGHT RATES REDUCED. 



George F. Hichborn, chairman of the Traffic Committee, an- 

 nounces that transcontinental rates from the Pacific coast on 

 carloads of crude rubber have been reduced to $1 per hundred- 

 weight and to $2.25 per hundredweight in less than carloads, these 

 rates efifective May 29, 1919. 



A joint meeting of the Executive Committees of the Pneumatic 

 and Solid Tire Manufacturers' Divisions was held May 14, 1919, 

 at 52 Vanderbilt Avenue, New York City, A. G. Partridge pre- 

 siding. The following were present : 



George M. Stadelman, chairman, Pneumatic Tire Manufactur- 

 ers' Division ; A. G. Partridge, chairman Solid Tire Manufactur- 

 ers' Division ; H. C. Miller, Joseph C. Weston, W. W. Duncan, 

 Maurice Switzer, T. S. Lindsey, A. H. Peterson, Horace De Lis- 

 ser, R. T. Grifiiths, Seneca G. Lewis, John A. Kearns, J. E. Baum, 

 and H. S. Vorhis, secretary; by special invitation, M. L. Hemin- 

 way and W. C. Arthur. 



The following members of the Special Committee on the Excise 

 Tax on Tires and Tire Accessories were present : F. C. Van 

 Cleef, Bernard M. Robinson, Kennedy M. Thompson, C. L. Lan- 

 don. and J. C. Weston. 



Important matters relating to the excise taxes on tires and 

 accessories were discussed and definite action taken toward modi- 

 fying certain features. 



It was voted that the Excise Tax Committee be increased from 

 seven to twelve members and that the following companies be 

 invited to name representatives: Ajax Rubber Co., Inc., Hood 

 Rubber Co., Lee Tire & Rubber Co., Empire Rubber & Tire Corp., 

 General Tire & Rubber Co. 



Horace DeLisscr was appointed a member of the Executive 

 Committee of the Pneumatic Tire Manufacturers' Di\ision. suc- 

 ceeding H. L. McClaren, resigned. 



The next meeting of the Pneumatic Tire Manufacturers' Di- 

 vision and the Solid Tire Manufacturers' Division will he held 

 at the Hotel Chalfonte, Atlantic City. New Jersey. June 23. 1919, 

 at 2.30 p. m. 



COMMENT ON TREASURY REGULATIONS RELATING TO EXCISE 

 TAXES ON TIRE AND TIRE ACCESSORIES. 



May 14, 1919. 

 To firm meynbers of The Rubber .issociaHon of America: 



The special committee appointed in the matter of the Federal excise 

 tax on the sales of tires, inner tubes, parts and accessories, submits the 

 following comment with reference fo Regulations 47 approved under date 

 of May 1, 1919, by the Treasury Department, a copy of which regulations 



is sent you by this mail. Of these regulations the following articles affect 

 particularly the manufacturer of automobile tires, inner lubes, parts and 

 accessories, and should be carefully studied by every such manufacturer: 

 Articles 1-16, Inclusive. Articles 34-52', Inclusive. 

 Certain of these articles seem to require special comment or explana- 

 tion, since they appear to be in either real or apparent conflict with a 

 portion of the contents of the letter of March 11, 1919, issued by The 

 Rubber Association. Treasury Department Regulations 47, taken in con- 

 nection with the contents of this letter, should be considered as supersed- 

 ing and replacing the letter of March 11, 1919. 



I. BASIS OF TAX. 



Articles 3, 4 and 34 of Regul.\tions 47. 



It is recommended that the tax be billed as a separate item and not 



included in the price of the article. Articles 3 and 4 of Regulations 47 



stipulate the method to be followed in determining the basis on which 



rticle 34, the tax on sales at 



ales 



to be computed. As sU 

 based on the actual price for which the article is sold, and on 

 ail is based on the average price at which the manufacturer 

 ■ne article at wholesale during the preceding month. No cash 

 an be deducted in computing the price on which the tax is 



The law requires that as to wholesale sales, taxes shall be collected 

 on the actual amount of the sale price. Many manufacturers have two 

 or more wholesale prices, as for instance manufacturers who sell at one 

 price to jobbers and distributers, and at another price to retail dealers. 

 Thus if a manufacturer sells a given tire for $50 to a jobber, the tax 

 would be $2.50, but if the same tire were sold to a dealer for $60, the 

 tax would be $3. Thus, this same tire from this same manufacturer 

 would, if sold through the dealer at $60, get to the consumer with $3 

 tax. but if sold at $50 through the jobber, it would get to the consumer 

 with a $2 tax. The many disadvantages to the manufacturer of such a 

 course and the obvious unfairness to the dealer are quite apparent. 



Therefore, in order that the tax paid by the consumer on products 

 of rubber manufacturers may be uniform in each case, regardless of 

 whether the goods are distributed by a manufacturer direct to a dealer 

 or through the intermediate channel of a jobber or distributer, it is sug- 

 gested that all products of rubber manufacturers sold to the wholesale 

 trade be sold on the same price base and that in the case of jobbers or 

 distributers to whom exfa discounts are allowed in fact not as dis- 

 counts on the sale price of the article, but as reimbursement for storage, 

 delivery and other services rendered in behalf of the manufacturer, such 

 extra discounts be regarded as a commission or service payment to the 

 jobber, and that they be paid by the issuing of a credit memorandum to 

 the jobber, or by other suitable method which will make the extra discount 

 transaction with the jobber or distributer one separate from the sale of 

 the article. 



Commissions to agents and other expenses of sale are not deductible 

 from the price. If articles are sold at the factory and the freight charges 

 from the factory to the point of delivery are paid by the buyer as a 

 specific item, or if they are sold delivered at a sum less freight charges 

 to be paid by the purchaser, such charges need not be included as part of 

 the price of the goods; but if the manufacturer sells goods at a delivered 

 price and himself pays the freight, he is not entitled to make any deduc- 

 tion on account of the inclusion in the price of freight charges. If the 



II. ADJUSTMENTS, REPLACEMENTS AND EXCHANGES. 



Art 



RLGt 



Where adjustments, exchanges or replacements of tires and tubes are 

 made by the manufacturer thereof with others than the manufacturers, 

 producers or importers of the automotive vehicles enumerated in the 

 Section 900, Subdivision 1 and 2 (except where the goods were not 

 originally tax-paid — see second paragraph below), the tax charged the cus- 

 turner should be computed on the exact amount, if any, paid by the customer 

 for the tires and tubes delivered by the manufacturer in making the 

 adjustment, exchange or replacement. Thus, where a customer returns 

 for adjustment a $50 tire and the manufacturer gives the customer a $50 

 tire, allowing $25 for the old tire, and receives from the customer a 

 differential of $25 for the new tire given in adjustment, the tax charged 

 to the customer should, be $1.25 or 5 per cent of the $25 (the amount 

 paid by th» customer). 



In opposition to the former verbal ruling of which you were advised on 

 page 6 of the letter of March 11, 1919, the Treasury Department has now 

 ruled that where tires and tubes, on which at the time of the original 

 sale the tax was not paid, are adjusted, exchanged, or replaced, the tax 

 to be then paid shall be based on the full price of the tire or tube 

 delivered in the adjustment, replacement or exchange. Thus, if a $50 

 tire sold prior to February 25, 1919, were presented for adjustment in 

 March, 1919, and replaced by a $50 tire for which the manufacturer 

 receiver! $25, a tax of $2.50 (i. e., 5 per cent of $50 instead of 5 per cent 

 of $25, the price received) must be paid to the Government. 



It appears to this committee quite impracticable and impossible for tire 

 manufacturers to determine whether or not tires and tubes returned for 

 adjustment were or were not tax-paid at the time of their original sale 



