United States Supreme Court Cases & Opinions

U.S. Supreme Court

United States v. Stewart, 311 U.S. 60 (1940)

United States v. Stewart

No. 13

Argued October 17, 1940

Decided November 12, 1940

311 U.S. 60

Syllabus

1. The exemption from taxation granted by § 26 of the Farm Loan Act of 1916 to farm loan bonds and the "income derived therefrom," does not apply to income derived from dealings or transactions in such bonds, and such income is taxable under § 22(a) of the Revenue Act of 1928. Applying Willcuts v. Bunn, 282 U. S. 216. Pp. 311 U. S. 61, 311 U. S. 63.

2. Acts of Congress which are in pari materia are to be taken together, as if they were one law. P. 311 U. S. 64.

3. The later of Acts which are in pari materia may be regarded as a legislative interpretation of the earlier, and is entitled to great weight in resolving doubts and ambiguities. P. 311 U. S. 64.

4. The Farm Loan Act of 1916 and the Revenue Act of 1916 (enacted shortly afterward at the same session of Congress) are in pari materia. That, in the case of farm loan bonds the latter Act, like the Revenue Act of 1928, expressly exempts income from "interest" alone is persuasive that the former does not exempt capital gains. P. 311 U. S. 64.

5. The conclusion that § 26 of the Farm Loan Act does not exempt income derived from dealings or transactions in farm loan bonds is not inconsistent with its legislative history or administrative interpretation. P. 311 U. S. 65.

6. The provision of § 817 of the Revenue Act of 1938, that "all income, except interest, derived" from farm loan bonds shall be included in gross income cannot be regarded as having been intended to change the previously existing law so far as the question involved in this case is concerned. P. 311 U. S. 66.

7. An analysis of numerous other exemption statutes is of little weight under the circumstances in determining the meaning of "income derived therefrom" in § 26. P. 311 U. S. 69.

8. The Farm Loan Board was without authority to make representations that capital gains from dealings in farm loan bonds were not taxable, and statements by the Board, which a purchaser so interpreted and on which he relied, cannot be accorded the weight of uniform and long established administrative treatment. P. 311 U. S. 70.

9. An officer or agency of the United States to whom no administrative authority has been delegated cannot, even by an affirmative

Page 311 U. S. 61

undertaking, waive or surrender a public right, and thereby estop the United States. P. 311 U. S. 70.

10. Exemptions from taxation may not rest upon mere implication, and statutory provisions granting exemptions are to be strictly construed. P. 311 U. S. 71.

106 F.2d 405 reversed.

Certiorari, 309 U.S. 647, to review the reversal of a judgment against the taxpayer, 24 F.Supp. 145, in a suit to recover a refund of income taxes.