Joseph McKenna

“ Replying to the contention that the purpose of Congress was not to tax any one but the manufacturer of a completed shell or the maker of a completed part of a shell, and that the forging of the Whell Company was not a completed part of a shell, the Court of Appeals said:
'It is manifest that, standing alone, the statute neither expresses nor implies any warrant or implication for limiting the broad, inclusive, generic words 'any part' to the restricted, specific, qualified term 'any completed part. ”

“ They are, besides, not in point. In the first one the statute had the words 'wholly manufactured,' and, giving effect to them, it was decided that boxes made from shooks imported from Canada, though nailed together and the sides of the boxes thus formed trimmed in the United States, were not boxes 'wholly manufactured' in the United States, and entitled, upon being exported, to a drawback under a statute which allowed a drawback on articles 'wholly manufactured of materials imported.' The Worthington Case was cited. ”

“ To fulfill such shell contract the contractor made subcontracts with the Forged Steel Wheel Company, by which the latter agreed to manufacture and furnish to said contractor, rough steel sheel forgins of the character provided in the contract, as to chemical constituents, tensile strength, size, shape, etc. To fulfill its contract, the Forged Steel Wheel Company either made, had made, or bought in the market, the grade of steel required. ”