Charles Evans Hughes

“ It is urged that in the provision of section 64a, as amended by Act May 27, 1926, § 15, 44 Stat. 666, 11 U.S.C.A. § 104 (a) , specifying the priority of taxes owing by the bankrupt, a 'municipality' is specifically named. The United States and the states are also specifically named in that provision and again in section 64b (7) . But we think that the failure to repeat the word 'municipality' in section 64b (7) cannot be regarded as controlling in view of the express inclusion of 'corporations' in that subdivision.
In construing the words of an act of Congress, we seek the legislative intent. ”

“ The words, 'having any of the powers and privileges of private corporations not possessed by individuals or partnerships,' do not mean, as the context plainly shows, that those described must be 'private corporations,' but that the term embraces those which have powers and privileges analogous to those of private corporations and not possessed by individuals or partnerships. Municipal corporations have such powers and privileges and thus fall within the definition of the term 'corporations' as used in the Bankruptcy Act. ”

“ The question is presented whether a municipal corporation is a 'person' within the meaning of this section. The word 'person' is expressly stated to include corporations. A municipal corporation is a corporation in the usual sense of the term. ”