High v. Coyne,
178 U.S. 111 (1900)

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U.S. Supreme Court

High v. Coyne, 178 U.S. 111 (1900)

High v. Coyne

No. 225

Argued December 5-7, 1899

Decided May 14, 1900

178 U.S. 111


The assignments of error in this case raised only the constitutionality of the taxes sought to be recovered, which has just been decided adversely to the plaintiffs in error in Knowlton v. Moore, ante, 178 U. S. 41, and there is nothing in the record to enable the court to see that the statute was mistakenly construed by the collector, but as the interpretation of the statute which was adopted and enforced by the officers administering the law was the one held to be unsound in Knowlton v. Moore, the ends of justice require that the right to resist so much of the tax as may have arisen from the wrong interpretation of the statute should not be foreclosed by the decree of this Court.

The complainants, who are appellants here, filed their bill to enjoin the executrix of their father's estate from paying the legacy taxes levied by sections 29 and 30 of the War Revenue Act of 1898. The collector of internal revenue was also made a defendant, and an injunction was asked against him to prevent his collecting or attempting to collect the taxes in question, which, it was asserted, he was about to enforce against the executrix, who, it was averred, would pay unless by the writ of injunction she was forbidden to do so. As heirs of their father and as beneficiaries of his estate, the complainants asserted they were entitled to prevent the executrix from making payment of taxes which were unconstitutional, and hence void. The reasons relied on to show that the taxing law was repugnant to the Constitution of the United States were that the taxes were direct, and not apportioned, were not uniform, and were levied on objects

Page 178 U. S. 112

beyond the scope of the authority of Congress. The bill was demurred to as not stating ground for relief. The demurrers were sustained, and from a decree dismissing the suit, this appeal is prosecuted.

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