Miller v. Standard Nut Margarine Co.,
284 U.S. 498 (1932)

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U.S. Supreme Court

Miller v. Standard Nut Margarine Co., 284 U.S. 498 (1932)

Miller v. Standard Nut Margarine Co. of Florida

No. 251

Argued January 6, 1932

Decided February 15, 1932*

284 U.S. 498


1. A suit to restrain collection of an excise imposed under the Oleomargarine Act is a suit to restrain collection of a tax, within the meaning of R.S. § 3224, and not a suit to collect a penalty. P. 284 U. S. 506.

Page 284 U. S. 499

2. Tax laws are to be interpreted liberally in favor of taxpayers; words defining things to be taxed may not be extended beyond their clear import; doubts must be resolved against the Government and in favor of the taxpayer. P. 284 U. S. 508.

3. R.S. § 3224 is declaratory of the equitable rule that a suit will not lie to restrain the collection of a tax upon the sole ground of its illegality, and it should be construed as nearly as may be in harmony with that rule and the reasons upon which it rests. P. 284 U. S. 509.

4. The section is general, and should not be construed as abrogating, by implication, the other equitable principle which permits suit to restrain collection where not only is the exaction illegal, but there exist special and extraordinary circumstances sufficient to bring the case within some acknowledged head of equity jurisprudence. Id.

5. The Oleomargarine Tax Act, before the Amendment of July 10, 1930, did not apply to substances resembling butter but containing no animal fat. P. 284 U. S. 506.

The product in question was made exclusively of cocoanut and peanut oils, salt, water and harmless coloring matter, and was sold for cooking, baking and seasoning.

6. Plaintiff made and sold a product not taxable under the Oleomargarine Act in reliance upon determinations by courts and the Commissioner of Internal Revenue interpreting the Act as inapplicable in like cases and upon assurance from the Bureau that its product would not be taxed. Later, the Commissioner changed his ruling, and, while not attempting to collect from other makers of like products who had obtained injunctions in which he had acquiesced and which had become final, directed that the tax be enforced against plaintiff's entire product from the beginning. This would have destroyed the business, ruined the plaintiff financially, and inflicted loss without remedy at law. Held that the Commissioner's action was not only based upon an erroneous construction of the statute, but was arbitrary and capricious, and that a suit could be maintained in the circumstances to enjoin the collection. Pp. 284 U. S. 508-510.

42 F.2d 79, 85, affirmed.

Certiorari to review affirmances of two decrees permanently enjoining collectors from collecting taxes imposed under the Oleomargarine Tax Law prior to the 1930 Amendment.

Page 284 U. S. 502

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