the absence of specific authority of Congress to that effect. (Article 315, Customs Regulations 1915. Chapter XXIII, Section 6.)

Dutiable Merchandise in Unsealed Packages

SEC. 8. Under special Postal Conventions entered into between the United States and Canada, Cuba, Mexico and the Republic of Panama dutiable articles may be imported into the United States through the mails in unsealed packages, subject only to the limitations as to value, weight or size, placed upon articles admissible to the domestic mails of the United States. (Article 297, Customs Regulations, 1915.)

Parcel Post

SEC. 9. Under the authority conferred by Section 398 of the Revised Statutes, parcel post conventions have been entered into with various foreign countries in regard to the importation of dutiable articles through the mails in unsealed packages.

Any article admissible to the domestic mails of the United States may be imported in unsealed packages by parcel post (unless a prohibited importation) from the following countries, with which the United States has parcel post conventions, viz.:

Australia, Austria (including certain Austrian offices in the Ottoman Empire), the Bahamas, Barbadoes, Belgium, Bermuda, Bolivia, Brazil, British Guiana, Chile, Colombia, Costa Rica, Curacao, Danish West Indies, Denmark, Dominican Republic, Dutch Guiana, Ecuador, France, French Guiana, Germany, Gibraltar, Great Britain,

Greece, Guadeloupe, Guatemala, Haiti, Honduras (British), Honduras (Republic of), Hongkong (colony), Hungary, Italy, Jamaica, Japan, Leeward Islands, Liberia, Mexico, Martinique, Netherlands, Newfoundland, New Zealand, Nicaragua, Venezuela, Windward Islands, China. (Article 296, Customs Regulations of 1915.)

Customs Declarations

SEC. 10. Importations of dutiable merchandise in unsealed packages by parcel post differ from those permitted through the ordinary mails under the exceptions heretofore mentioned, in that importations by parcel post must be accompanied by a customs declaration, prepared by the foreign sender in approved form, giving an accurate statement of the contents and value of the package.

Informal Mail Entry

SEC. 11. If the customs declaration attached to the parcel post package indicates a value not in excess of $100 informal mail entry may be made, based upon the customs declaration, without the production of a duly certified consular invoice. (Article 310, Customs Regulations 1915.)

Having so entered the parcel post package and having stated a value for the merchandise contained therein, the importer may appeal to reappraisement under Paragraph M of Section III of the Act of October 3, 1913, should the appraising officer make advances to the entered value on appraisement. (Chapter VII, Section 8.)

The importer may likewise file protest in writing under Paragraph N of Section III of the Tariff Act of October 3, 1913, if he deems the assessment

and liquidation of the duties as made by the collector too high. (Chapter VIII, Section 5.)

It is accordingly provided by Article 311 of the Customs Regulations of 1915 that informal mail entries will be formally liquidated and the date of liquidation stamped thereon, and that all entries. liquidated during any month may be stamped as liquidated on the last day of that month and so posted at the custom house..

It is against the date of liquidation so posted that the 30 days within which protest may be filed begins to run. (United States Court of Customs Appeals, U. S. v. Mandel Bros., T. D. 37051.) (Chapter VIII, Section 4.)

Formal Mail Entry

SEC. 12. If the customs declaration attached to the parcel post package indicates a value in excess of $100, formal or regular entry will be required, in accordance with the provisions of Section 2785 of the Revised Statutes, accompanied by a duly certified consular invoice or by a bond to produce such consular invoice.

Formal entry having been so made, the right to appeal to reappraisement and review on protest under Paragraphs M and N of Section III of the Tariff Act of October 3, 1913, accrues. (Article 313, Customs Regulations, 1915). (T. D. 37077.)

CHAPTER XXII

ERRORS IN THE ENTRY OR LIQUIDATION

Manifest Clerical Errors

SEC. 1. Manifest clerical errors in any entry or liquidation for or against the United States may be corrected within one year after entry under Paragraph Y of Section III of the Tariff Act of October 3, 1913, which provides:

"That whenever it shall be shown to the satisfaction of the Secretary of the Treasury that, in any case of unascertained or estimated duties, or payments made upon appeal, more money has been paid to or deposited with a collector of customs than, as has been ascertained by final liquidation thereof, the law required to be paid or deposited, the Secretary of the Treausury shall direct the Treasurer to refund and pay the same out of any money in the Treasury not otherwise appropriated. The necessary moneys therefore are hereby appropriated, and this appropriation shall be deemed a permanent indefinite appropriation; and the Secretary of the Treasury is hereby authorized to correct manifest clerical errors in any entry or liquidation for or against the United States, at any time within one year of the date of such entry, but not afterwards: Provided, That the Secretary of the Treasury shall, in his annual report to Congress, give a detailed statement of the various sums of money refunded under the provisions of this Act or of any other Act of Congress relating to the revenue, together with copies of the rulings under which repayments were made."

Under this section it is essential that the error complained of be manifest. A manifest clerical error has been defined by the Treasury Department, by the Board of United States General Appraisers, and by the United States Court of Customs Appeals, to be one that is manifest on the face of the papers forming the official record of the im

portation. To obtain relief it is not necessary that a protest under Paragraph N of Section III of the Act of October 3, 1913, be filed within thirty days after liquidation, but it is sufficient if attention is called to the error within the statutory limitation of one year after date of entry.

If, however, the importer elects to file protest under Paragraph N of Section III of the Tariff Act of October 3, 1913, which it is his privilege to do, such protest will be forwarded to the Board of United States General Appraisers for decision, as it invariably involves a question as to the amount of duties chargeable on the importation, and as such falls within the scope of Paragraph N of Section III of the Tariff Act of October 3, 1913 (Chapter VIII, Section 5).

Manifest clerical errors against the interests of the importer in any entry or liquidation not discovered until more than one year after entry can be corrected only if covered by protest meeting the requirements of Paragraph N of Section III of the Act of October 3, 1913. (Chapter VIII, Section 5.)

Errors in Classification.

SEC. 2. Errors in classification adverse to the interests of the importer in any entry or liquida tion involving the rate and amount of duties chargeable, discovered after liquidation, may be corrected only upon the filing of a protest in writing in due form within thirty days after liquidation as required by Paragraph N, Section III, Act of October 3, 1913, heretofore cited. (Chapter VIII, Section 5.)

Errors in classification adverse to the interests of the Government in any entry or liquidation involv