“ This man who owns a ship looks upon her as his wife or his children; he loves his ship; and, under the law as it stands to-day, he is required to paint on the stern the name, it may be that of his wife or of his daughter, and the port to which she belongs. For seventy-five years the port to which she belonged was construed to be the place where she was owned, and if a man built a ship in Surry, and she was owned there, he painted in the stern the 'May Ann, from Surry, Maine.' In 1875 a sharp Treasury official discovered that it was a violation of the law. ”

“ The existence of power in the state to tax the property in question was rested solely upon the proposition that, as the steamboats were enrolled at Paducah, and the name 'Paducah' was painted upon their sterns, it was to be conclusively presumed that the home port of the vessels was at Paducah, and that such home port was the situs of the property for taxation. ”

“ This clearly follows, since, in the Old Dominion Steamship Case, the right of the state of Virginia to tax was based upon the permanent situs of the vessels in Virginia, although they were enrolled in another state. ”

“ The name of every documented vessel of the United States shall be marked upon each bow and upon the stern, and the home port shall also be marked upon the stern. These names shall be painted or gilded, or consist of cut or carved or cast roman letters in light color on a dark ground, or in a dark color on a light ground, secured in place, and to be distinctly visible. The smallest letters used shall not be less in size than four inches. ”

“ Louis, in the state of Illinois. The company had an office in St. Louis, where its president and other principal officers lived, and where the ordinary business meetings of the directors were held and the corporate seal was kept. A tax was paid upon the boats in Illinois, the residence of the owner. The city of St. Louis taxed the ferry boats as personal property 'within the city.' It was, however, held that the boats did not so abide within the city as to become incorporated with and form part of its personal property, citing Hays v. Pacific Mail S. S.C.o. supra. ”