1. Gelston, a New York City merchant and Republican politician, had been a member of the New York Provincial Congress, the Continental Congress, the New York Assembly, the New York Senate, and the Council of Appointment. On July 9, 1801, Thomas Jefferson appointed him collector of customs for the District of New York during the congressional recess, and the Senate approved the appointment on January 26, 1802 (Executive Journal, I description begins Journal of the Executive Proceedings of the Senate (Washington, 1828), I. description ends , 403, 405). In 1802 Gelston was also a member of the New York Senate from the Southern District of New York.

This letter concerns two customs cases, The United States v The Brigantine Triton, John and William Howland, Claimants and The United States v Three Hundred Casks of Porter, Joshua Waddington, Claimant, in both of which H acted for Edward Livingston, United States attorney for the District of New York. For a discussion of these cases, H’s participation in them, and related documents, see Goebel, Law Practice description begins Julius Goebel, Jr., ed., The Law Practice of Alexander Hamilton: Documents and Commentary (New York and London, 1964–). description ends , II, 841–47.

2. See Section 10 of “An Act concerning the Duties on Spirits distilled within the United States” (1 Stat. description begins The Public Statutes at Large of the United States of America, I (Boston, 1845). description ends 267–71 [May 8, 1792]).