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Legislative Process Keyed to Bressman, 4th Ed.
United States v. Mead Corp.
Citation:
533 U.S. 218 (2001)Facts
Mead Corporation imported three-ring binders with pages for daily schedules, phone numbers, and addresses, known as “day planners.” Between 1989 and 1993, Customs consistently treated these day planners as duty-free under the “other” subheading of HTSUS 4820.10. In January 1993, Customs changed its position and issued a Headquarters ruling letter classifying the day planners as “Diaries…bound” subject to a 4% tariff under subheading 4820.10.20. After Mead’s protest, Customs issued a more detailed ruling letter maintaining the same conclusion, reasoning that “diary” included books with printed dates for daily memoranda, and that “bound” included items with ring bindings. Mead challenged this ruling in court, arguing that its day planners were not “diaries” because they lacked space for extensive notations about past events, and were not “bound” in the traditional bookbinding sense.
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