U.S. Supreme Court
United States v. Tappan, 24 U.S. 11 Wheat. 419 419 (1826)
United States v. Tappan
24 U.S. (11 Wheat.) 419
The words "true value," in the eleventh section of the Duty Act of 20 April, 1818, c., 361, mean the actual cost of the goods to the importer at the place from which they were imported, and not the current value of the goods at such place.
If the collector in fact suspects that the goods are invoiced below the current market value thereof at the place from which they were imported, but does not suspect that they were invoiced below the true and actual cost thereof to the importer, the collector has no right to direct an appraisement.
But whenever in the opinion of the collector there is just ground to suspect that the invoice does not truly state the actual cost of the goods, he may direct the appraisement, and is not bound to disclose the grounds upon which he forms that opinion, whether it is formed from his knowledge or information of the current market price of the goods or other circumstances affording grounds to suspect the invoice to be fraudulent.