Question juridique clé
Whether the appellant could invoke protection of good faith against subsequent customs duty recovery based on alleged oral assurances.
Solution extraite
The appellant failed to prove that any oral assurance to clear the goods at the tariff quota rate had been given; the good-faith protection therefore did not apply.
Motifs extraits
The testimony did not establish the alleged promises with the required certainty, especially given the unusual oral form and the limited evidentiary weight of the alleged telephone contacts. In customs matters, the burden of proving facts favorable to the taxpayer remains with the taxpayer.