Narrative Opinion Summary
Burroughs Corporation challenged the classification of its imported office machines by the United States Customs Service under item 676.15 of the Tariff Schedules of the United States, which imposed a 5.5% ad valorem duty. These machines, labeled as electronic desk calculators, transaction recorders, and transaction terminals, were argued by Burroughs to lack a 'calculating mechanism' as defined in Headnote 2(b), which traditionally requires performing basic arithmetic operations. Burroughs contended for classification under item 676.30, which carries a lower duty. The Court of International Trade, however, upheld Customs' classification, noting that 'calculating mechanism' includes integrated circuits and does not necessitate moving parts. Despite Burroughs' reliance on the definition from United States v. Texas Instruments Inc., the court determined it non-applicable due to industry differences. Legislative history was considered to understand Congress's intent, affirming that electronic components were within the scope of the term. The court concluded that the classification under item 676.15 was appropriate, affirming the judgment against Burroughs Corporation.
Legal Issues Addressed
Definition of Calculating Mechanismsubscribe to see similar legal issues
Application: The court affirmed that a calculating mechanism does not require moving parts and can include machines with integrated circuits, contrary to Burroughs' argument.
Reasoning: The Court of International Trade rejected Burroughs' argument that its machines lacked a calculating mechanism due to the absence of moving parts within the arithmetic logic unit.
Examination of Legislative Intentsubscribe to see similar legal issues
Application: The court emphasized the importance of legislative history to determine Congress's intent regarding the term 'calculating mechanism' in the context of TSUS.
Reasoning: Consequently, the court emphasized the need to examine legislative history to ascertain Congress's intent regarding 'calculating mechanism.'
Judicial Interpretation of Mechanismsubscribe to see similar legal issues
Application: The interpretation from United States v. Texas Instruments Inc. was considered, but the court found it not controlling for office machines, as it was specific to the horological industry.
Reasoning: Burroughs asserted that the definition of 'mechanism' from the Texas Instruments case should apply, but the Government contended that this case was not controlling since it pertained to the horological industry, which differed significantly from the computer industry at the time the TSUS was enacted.
Tariff Classification under TSUSsubscribe to see similar legal issues
Application: The classification of Burroughs Corporation's office machines under item 676.15 was upheld, indicating they are accounting, computing, and other data processing machines with a calculating mechanism.
Reasoning: The United States Customs Service classified them under item 676.15 of the Tariff Schedules of the United States (TSUS), imposing a 5.5 percent ad valorem duty, defining them as accounting, computing, and other data processing machines with a calculating mechanism.