On this point, one other consideration would show that the intent to save taxes could not have

existed in the minds

of the organizers of SM. The sales tax imposed, in theory and in practice, is passed on to the vendee, and is usually
billed separately as such in the sales invoice. As pointed out by petitioner Yutivo, had not SM handled the retail, the
additional tax that would have been payable by it, could have been easily passed off to the consumer, especially
since the period covered by the assessment was a "seller's market" due to the post-war scarcity up to late 1948,
and the imposition of controls in the late 1949.