Taxation — Corporate loans — Bonds issued by city — Payment of interest — Improvement bonds — Assessment against properties — Obligation not primarily debt of corporation — Acts of June 17, 1913, P. L. 507; July 15, 1919, P. L. 955, and July 13, 1923, P. L. 1085.
1. Under the Act of June 17, 1913, P. L. 507, as amended by the Acts of July 15, 1919, P. L. 955, and July 13, 1923, P. L. 1085, a city is liable for a tax upon improvement bonds issued by it, payable out of assessments levied against the properties benefited, carrying interest payable by the city. [204]
2. Under the Act of 1913, as amended, where a corporation (1) issues bonds or (2) assumes bonds or (3) pays the interest on them, they are taxable for state purposes, even though the obligation is not primarily a debt of the corporation paying the tax. [204-5]
3. The holder of the evidence of indebtedness primarily owes the tax; the treasurer of the corporation is the agent of the Commonwealth to collect the tax. [206]
Argued May 22, 1939.
PER CURIAM, June 19, 1939:
The judgment of the court below is affirmed upon the opinion of President Judge HARGEST.