George Sutherland

“ If to carry out the purposes of a statute it be admissible to construe the word 'person' as including the United States, it is hard to see why, in like circumstances, it is inadmissible to construe the word 'resident' as likewise including the United States.
And, finally, if the United States be not a 'resident' in respect of interest upon 'other interest-bearing obligations,' it is, of course, not a 'resident' in respect of interest upon its bonds held by nonresident aliens and corporations. The interest upon many of these bonds is subject to a superincome tax and to certain other taxes. ”

“ While it cannot be said that the United States, in its corporate capacity as an artificial person, has a bodily presence in any place, it is not unreasonable to hold that in the eye of the law it has a residence, and especially so when a contrary holding would defeat the evident purpose of a statute. ”

“ The general object of this act is to put money into the federal treasury; and there is manifest in the reach of its many provisions an intention on the part of Congress to bring about a generous attainment of that object by imposing a tax upon pretty much every sort of income subject to the federal power. Plainly, the payment in question constitutes income derived from a source within the United States; and the natural aim of Congress would be to reach it. ”