Edward Douglass White

“ It is equally unsound to divide the finding of fact so as to make it designate two distinct kinds of tobacco, thus: 'First, 'clippings from the ends of cigars;' and, second, 'pieces broken from the tobacco of which cigars are manufactured, in the process of such manufacture." The words 'in the process of such manufacture' qualify the whole sentence.
Resort to the provisions of the internal revenue laws regarding tobacco seems to us to strengthen, rather than to militate against, our conclusion. Various provisions of these laws have been brought to our attention. ”

“ We think the context of these sections makes it clear that their general purpose and object was to regulate the manufacture and disposition of all classes of tobacco, and that they conform, by a fair construction and interpretation, to the view that the scraps are neither a manufactured, nor a partially manufactured, article. We are here dealing with the waste or the scraps, not from the internal revenue point of view, but as an article of commerce, separate from the manufacturer and the factory. ”

“ The fact that it directs the manner in which the scraps and refuse shall be put up in the factory affords no evidence of a legislative determination that the scraps themselves are manufactured articles. Nor does section 59 of the same act justify the interpretation which is sought to be placed upon it. On the contrary, it distinguishes scraps by fair implication from both manufactured and partially manufactured tobacco. ”