Welch

Plaintiff paid a federal stamp tax, collected on account of a series of certificates issued by it in its business of buying and selling commercial securities. While in effect the transactions may have been substantially that of the purchase of securities on a margin, the plaintiff chose to frame its contracts differently. The purchaser signed a written order for' the purchase of securities on installment payments, agreeing to pay the stated purchase price with interest at the rate of 7 per cent, per annum, with the right to make full payment at any time-; he agreed to pay a fee to the plaintiff called “investment counsel fee,” and the plaintiff had the right in the event of default in payment of any installment to terminate the contract, close out the stocks, and account to the purchaser for any net remaining after deducting charges. However, plaintiff, as evidence of the interest *501 acquired by the purchaser, issued an elaborate certificate, formed and printed in the manner usual with stock certificates and bonds. On the face of this certificate the transaction was denominated “Investment Savings Plan.” It set forth that the City Bond & Finance Company had agreed to “sell and…