William O. Douglas

“ Support for that conclusion was found in the title of the 1953 Act which includes the words 'excepting from repeal certain taxes,' no qualifications whatsoever being indicated.
We take a different view. Section 2 (a) of the 1953 Act, as we read it, has nothing to do with any taxes other than those payable to a municipality, a school or public utility district, none of which is here involved. If it had done no more than save all accrued taxes in those categories, the case would be in quite a different posture. ”

“ The judgment of the Court of Appeals is reversed and, as there are other questions which were raised by the appeal (9 Cir., 246 F.2d 493, 495) but not reached by that court, the cause is remanded to it for proceedings in conformity with this opinion. It is so ordered. ”

“ It saved first, those taxes that had been 'levied and assessed' and second, those to be 'levied and assessed during the current fiscal year.' This was to make sure, as the dissent below said, that municipalities and school and public utility districts (though not the Territory itself) would have the right to levy and collect the old taxes for the current year 1953, whether before or after the repealing Act had taken effect. So construed, § 2 (a) carves no exception from the general saving statute and does not interfere with the collection of unpaid taxes which accrued prior to repeal. ”