Morrison Waite

“ We think it would hardly be claimed that if a private individual, living in one of the loyal states during the war, derived an income, which he actually reduced to possession, or used in the payment of debts, from property in confederate territory, he would be exempt from the income tax imposed on him by the internal-revenue laws, because of the source from which his income was derived. ”

“ U.S., it was held that the internal-revenue tax on interest and dividends was an excise tax on the business of corporations, to be paid by the corporations out of their earnings, income, and profits. The payments made in this case were for dividends to stockholders and interest to bondholders out of the earnings, income, and profits of the corporation in its business. By means of the dividend the surplus earnings were distributed to the stockholders, and the debts of the company were discharged to the extent of the interest paid. ”

“ The corporation was, therefore, subject to the actual governmental control of the United States, and the laws of the United States were both operative upon and enforceable against it. No one will deny that the internal-revenue laws were intended to reach all persons and corporations within the dominion of the United States against whom they could for the time being be enforced by judicial process or otherwise. ”