HIGH
v.
COYNE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
A taxpayer challenged the constitutionality of taxes levied under sections 29 and 30 of the War Revenue Act, arguing they violated the Constitution. The Supreme Court affirmed the lower court's dismissal of the complaint, holding that all constitutional objections to the taxes had been previously decided adversely in Knowlton v. Moore, but preserved the taxpayer's right to contest any portion of the tax assessment that may have resulted from erroneous statutory interpretation by tax officials.
© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Mr. Justice White delivered the opinion of the court.
As the court below did not grant an injunction, but dismissed the bill, it is unnecessary to consider whether the right would have existed to enjoin the collector of internal revenue even had the court concluded that the averments of the bill disclosed a cause of action. Rev. Stat. 3226.
Every ground relied on to maintain that the taxes levied by sections 29 and 30 of the War Revenue Act are repugnant to the Constitution has been decided adversely in the opinion this day announced in Knowlton v. Moore.
This disposes of this case, as the assignments of error raised only the constitutionality of the taxes, and there is nothing in the record to enable us to see that the statute was, by the collector, mistakingly construed.
As, however, the interpretation of the statute, which was held to be unsound in No. 387, was the one which was adopted and enforced by the officers charged with the administration of the law, the impression naturally arises that such erroneous construction must have been applied in assessing the tax in controversy. The ends of justice therefore require that the right to resist so much of the tax as may have arisen from the wrong interpretation of the statute above referred to be not foreclosed by our decree.
Decree affirmed, without prejudice to any such right.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By (11 total)
-
Walker v. United States, 83 F.2d 103 (8th Cir. 1936)…t. 779, 44 L.Ed. 1014; Murdock v. Ward, 178 U.S. 139, 20 S.Ct. 775, 44 L.Ed. 1009; Plummer v. Coler, 378 U.S. 115, 134, 20 S.Ct. 829, 44 L.Ed. 998; Fidelity Ins. Trust & S. D. Co. v. McClain, 178 U.S. 113, 20 S.Ct. 774, 44 L.Ed. 998; High v. Coyne, 178 U.S. 111, 112, 20 S.Ct. 747, 44 L.Ed. 997; Knowlton v. Moore, 178 U.S. 41, 47, 20 S.Ct. 747, 44 L.Ed. 969; Magoun v. Illinois Trust & Savings Bank, 170 U.S. 283, 288, 18 S.Ct. 594, 42 L.Ed. 1037. Also see Industrial Trust Co. v. United States, 296 U.S. 220,…1 / 3
-
Jasper L. House, Jr. v. Commissioner OF Internal Revenue, 453 F.2d 982 (5th Cir. 1972)…must be obeyed.” 2 L.Ed. at 313. (Emphasis supplied.) See also, United States v. Palmer, 16 U.S. (3 Wheat.) 610, 4 L.Ed. 471, 477 [*988] (1818); and Smythe v. Fiske, 90 U.S. (23 Wall.) 374, 23 L.Ed. 47, 49 (1874). In Knowlton v. Moore, 178 U.S. 41, 20 S.Ct. 747, 756, 44 L.Ed. 969, 978-979 (1899), the Court said: “On the very threshold, the theory that the tax is not on particular legacies or distributive shares passing upon a death, but is on the whole amount of the personal property of the deceased, is r…
-
Porto RICO Tax Appeals. Insular Motor Corp. v. Gallardo, 16 F.2d 545 (1st Cir. 1926)…L. Ed. 884, 44 A. L. R. 1454; Billings v. United States, 232 U. S. 261, 280, 281, 34 S. Ct. 421, 58 L. Ed. 596; Flint v. Stone Tracy Co., 220 U. S. 107, 151, 152, 31 S. Ct. 342, 55 L. Ed. 389, Ann. Cas. 1912B, 1312; Knowlton v. Moore, 178 U. S. 41, 20 S. Ct. 747, 44 L. Ed. 969. V. Pending these appeals, under order of court, the taxes in question have been impounded in the hands of the clerk of the court below. The results are: (1) In Hos. 1944, 1945, 1946, 1947 and 1949, there must be decrees providing f…
Previewing 3 of 11 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligence