"Stacked" Use of R184s on a Stock Sale Memorandum

Stamp washing and reuse was somewhat common on the 1898 dollar values, prompting ink experimentation that would help prevent effective cancel washing, and rules regarding stamp cancellation that required not only ink cancellation but mutilation through cuts or punch-outs.  

By late 1899, cancel washing and stamp reuse had become so common that the Commissioner of Internal Revenue made it mandatory for all revenue stamps of 10 cents or more be mutilated by three parallel cuts into the stamp.  So from January 1900, many of the dollar denominated revenue stamps are found with cut cancels.  The regulation seems to have been mostly ignored for the documentary battleships.

Today is featured 8 $1 stamps that have been appropriately cut cancelled.  However, they have been stacked on a stock sale memorandum.  While the regulations regarding cancelling don't address stacking the stamps this way, I do not believe this way of applying the stamps to the document would have been approved by revenue agents.

A Malcom & Coombe sale memorandum to Eames & Moore for 400 shares of Southern Railway requiring $8 of revenue stamps:

The stamps are stacked rather than spread out across the memo, making it difficult on quick inspection to insure that $8 worth of stamps were used.  Careful inspection indicates that there are 4 pairs of $1 stamps.

On the right side it is possible to see four layers of stamps

Reverse side of sale memo, focusing on the area behind the stamps.  The cut cancels penetrate all of the stamps and through the memo.

The main problem I see with this way of applying the stamps is that the bottom 6 stamps could have been used previously, all cancelled with ink and cuts, and we would never know as they are covered by the top two stamps.  Clearly, this way of applying high value stamps to documents is not common, as this is the first instance of stamp stacking I've come across on stock sale memos.  I am fairly sure that revenue agents would have fully disapproved of this practice.

I wanted to check whether there may have been a specific prohibition against this practice.  An 1899 internal revenue circular spoke to the new requirment for 3 parallel cut cancels.

Though certainly published in December 1899, the content of a circular from the US Commissioner of Internal Revenue was reprinted in The Official Gazette of the United States Patent Office, January 16, 1900:

A review of section six of the earler 1898 war revenue law makes no mention of a prohibition of stacking stamps before cancelling them.  However, the law does say:

That in any and all cases where an adhesive stamp shall be used for denoting any tax imposed by this Act, except as hereinafter provided, the person using or affixing the same shall write or stamp thereupon the initials of his name and the date upon wich the same shall be attached or used...

It seems to me that it is implicit that in order for the above to be enforced, all the stamps on the document must be visible.  At least in this sense the stacking on the Malcom & Coombe memo is not permitted.

Certainly, stacking wasn't necessary to fit all the stamps on the memo of sale.  Here are two examples of extensive real estate use on stock sale memos:

Mr. Feuchtwanger sold 600 shares of Southern Railway to Eames & Moore, requiring $12 of revenue stamps.  He or his clerk placed 12 $1stamps on the reverse side of the memo.

A. H. Combs & Company sold 1500 shares of Texas Pacific, requiring $30 of revenue stamps.  11 $2 stamps were placed on the front of the memo; 4 on the reverse.