Samuel Freeman Miller

“ It is, beyond question, a revenue law, and the offence defined by it is therefore a crime arising under the revenue laws of the United States.
With regard to the first two counts the answer is not so clear.
The gravamen of the offence here is the conspiracy. For this there must be more than one person engaged. ”

“ Although by the statute something more than the common-law definition of a conspiracy is necessary to complete the offence, to wit, some act done to effect the object of the conspiracy, it remains true that the combination of minds in an unlawful purpose is the foundation of the offence, and that a party who did not join in the previous conspiracy cannot, under this section, be convicted on the overt act. ”

“ The force of the argument arising from finding an enactment in a statute directed mainly to a particular subject is much diminished by our experience of the manner in which incongruous legislation is combined in the same bill as passed by the two Houses of Congress. ”