“ Rep. 184, an action to recover duties paid under protest is now based entirely on a statutory liability, which is regulated as to all its incidents by express statutory provisions. Among such regulations is the one that the payment of the duties shall have been made, not only under protest, but also in order to obtain possession of the imported merchandise, in order to authorize the action to recover back the duties. ”

“ There are no separate findings of fact and of conclusions of law, nor is there any general finding for either party; but there is accompanying the record an opinion of the court, which is reported in 15 Fed. ”