XXIV 
INTERNAL REVENUE TAXATION 
Duties are never imposed on the citizens upon vague or doubtful interpreta- 
tions. (Hartranft v. Weigmann, 121 U. S. 609, and cases there cited.) 
Extrinsic aids: Words spoken by members in debate, or the motives of mem- 
bers, not to be considered in construing statutes; but courts in construing a 
statute may, with propriety, recur to the history of the times when it was 
passed. (United States v. Union Pacific Railroad Co., 91 U. S,, 72-79.) 
Debates in Congress as sources of information for construction of statutes. 
(27 Op. Atty. Gen., 68.) 
The courts may look to the history of the legislation upon the subject of 
which the statute treats, and the history of the times in which it was enacted, 
as well as the general history of the country, to determine the purpose that the 
Government sought to accomplish. (Church of the Holy Trinity @. United 
States, 143 U. S., 457.) 
In case of ambiguity in a statute contemporaneous and uniform executive con- 
struction is regarded as decisive. (Brown vo. United States, 113 U. S., 568; 
also decisions cited by Attorney General in letter to Secretary of Treasury, 
November 17, 1885, 31 Int. Rev. Rec, 382; Nunn ». Gerst Brewing Co., 99 
Fed., 941.) 
Where the language of a series of statutes is dubious, and open to different 
interpretations, the construction put upon them by the executive department 
charged with their execution has great and generally controlling force with the 
court. (St. Paul, Minneapolis, etc.,, Railway Co. v. Phelps, 137 U. S., 528; see 
19 Op. Atty. Gen., 177.) 
A construction of a doubtful or ambiguous statute by the executive depart- 
ment charged with the execution, in order to be binding upon the courts, must 
de long continued and unbroken. (Merritt v. Cameron, 137 U. S., 542.) 
It is a rule well established that the construction given to a statute by those 
charged with the duty of executing it will be given great weight by the courts 
if the true construction be doubtful (United States v. Hill, 120 U. S., 169, and 
cases cited, p. 182) ; but this rule has no application where the statute is not 
ambiguous or where it will not bear the interpretation put upon it by the 
executive officers. (Swift Co. ». United States, 105 U. S., 691, 695: United 
States v. Graham, 11¢ U. S., 219; United States v, Tanner, 147 U. S. 661: 
United States v. Alger, 152 U. S., 384, 397.) 
A long-continued and uniform interpretation, put by the executive and legis- 
lative departments of the Government, upon a clause in the Constitution should 
be followed by the judicial department unless such interpretation is manifestly 
contrary to its letter or spirit. (Downes v. Bidwell, 182 U. S., 244.) 
A uniform construction by the department, put upon a doubtful statute, has 
great weight with the court in construing it, and, where the practice hds been 
followed for a long time, the court will accept the department’s interpretation 
as the proper one. (United States v. Twitchell Co., 184 Fed., 526.) 
While an act of Congress must be accepted for the purpose of interpretation 
n the form in which it was finally passed, and can not be altered or amended 
to conform to the meaning given it by individual Members who advocated its 
passage, or by a committee which may have discussed it in a report, such ex- 
pressions of opinion are entitled to weight in construing the law. (Penn. Mut. 
Life Ins. Co. ». Lederer, 247 Fed., 559; reversed on another point by 258 
Fed., 81.) 
Construction with reference to other laws: Statutes in pari materia are to be 
construed together, and repeals by implication are not favored if the acts can 
reasonably stand together. (Harrington's Distilied Spirits, 11 Wall, 356, 13 
Int. Rev. Rec., 193; United States ». 100 Barrels of Spirits, 12 Id., 153; United 
States v. Cook County National Bank, 25 1d., 266.) 
Internal-revenue acts should be interpreted in harmony with the tariff legis 
lation of the country. (Taylor ». Treat (1907), 153 Fed., 656.) 
It is a settled rule that where there are two consistent acts relating to the 
same subject, effect is to be given to both of them. (Chicago, ete., ». United 
States, 127 U. 8., 406; Landram wv. United States, 118 U. S., 81; 32 Int. Rev. 
Ree., 151.) 
General laws relating to internal revenue not affected by subsequent laws. 
Subsequent legislation does not supersede general laws unless the contrary 
clearly appears. (United States ». Barnes, 222 U. S., 513; T. D. 1751.) 
Where there are two acts upon the same subject they must stand together if 
possible. . (28 Op. Atty. Gen., 70.)