Yazoo & Mississippi Valley R. Co. v. Adams, 181 U.S. 580 (1901)

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Yazoo & Mississippi Valley Railroad Company v. Adams


No. 36


Leave to file petition for rehearing granted February 25, 1901
Decided May 20, 1901
181 U.S. 580

ERROR. TO THE SUPREME COURT
OF THE STATE OF MISSISSIPPI

Syllabus

The railroad company filed a bill to enjoin the collection of certain state taxes from 1892 to 1897 inclusive. This Court held that a new corporation was formed by a consolidation of certain prior corporations made October 24, 1892, and that the taxes having accrued subsequent to that date were legally assessed under the state constitution of 1890, (180 U.S. 1). The railroad company moved for a rehearing with respect to the taxes of 1892 upon the ground that they accrued prior to the consolidation of October 24. Held that, as the Supreme Court of Mississippi had decided that all the taxes had accrued after the consolidation of October 24, and the company had thereby lost its exemption, and as this was a construction of the general tax laws of the state, which were complex and difficult of interpretation, this Court would accept that construction and deny the petition for a rehearing.

This was a petition for a rehearing of the case reported in 180 U.S. 1, upon the ground that the taxes for the year 1892 were separable from taxes for the succeeding years, inasmuch as the taxes for that year had been completely levied and assessed on September 22, 1892, and that the claim of the state, if any, had fully accrued at least one month before the articles of consolidation were executed (October 24, 1892), and that the judgment therefore gave to the consolidation a retrospective effect.