“ Section 6 of the war revenue act of 1898 provided that there should be 'levied, collected, and paid' in respect of the instruments mentioned, 'by any person or persons or party who shall make, sign, or issue the same, or for whose use or benefit the same shall be made, signed, or issued, the several taxes or sums of money' set forth in the schedule which followed. There is nothing in the nature of a stamp tax which per se negatives either the personal obligation, otherwise to be derived from the words imposing the tax, or its collection by action. ”

“ It appears to us clear upon principle, as well as upon the obvious import of the provisions of the various acts of Congress on this subject, that the duties due upon all goods imported constitute a personal debt due to the United States from the importer (and the consignee for this purpose is treated as the owner and importer) , independently of any lien on the goods, and in any bond given for the duties. ”

“ The statute now before us fixes a tax of a specified amount, according to the consideration or value of the lands conveyed.
It is insisted, however, that the provision for penalties excludes the idea of a personal liability. Thus it is made a misdemeanor to sign or issue one of the described instruments to which a stamp has not been affixed, punishable under § 7 by a fine of not more than $100, and not exceeding $200 under § 10, in the case of a bill or note. ”

“ The statute, in imposing the per centum of tax on the income of the individual, makes a charge on him of a sum which is certain for the purposes of an action of debt, because it can be made certain through the action of a judicial tribunal, by following the rules laid down in the statute. ”

“ It applies and it is enforced whan anyone to whom the statute is a rule of conduct seeks redress for a civil wrong. He is confined to the remedy pointed out in the statute, for he is forbidden to make use of any other. But by the internal revenue law, the United States are not prohibited from adopting any remedies for the recovery of a debt due to them which are known to the laws of Pennsylvania. The prohibitions, if any, either express or implied, contained in the enactment of 1866, are for others, not for the government. They may be obligatory upon tax collectors. ”

“ The question presented is whether an action lies by the United States to recover the amount of a stamp tax payable under the war revenue act of 1898 upon the execution of a conveyance.
If the statute creates an obligation to pay the tax, and does not provide an exclusive remedy, the action must be regarded as well brought. ”

“ The portion of this section which imposes the penalty is of comprehensive scope, and must be deemed to include a conveyance of land, as well as the other instruments within the purview of the statute. ”

“ They may prevent any suit at law by such officers or agents. But they are not rules for the conduct of the state. It is a familiar principle that the King is not bound by any act of parliament unless he be named therein by special and particular words. ”