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Merchants National Bank v. United States, 214 U.S. 33 (1909)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Merchants National Bank v. United States, 214 U.S. 33 (1909)
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Merchants National Bank of Baltimore v. United States No. 20 Argued March 12, 15, 1909 Decided May 17, 1909 214 U.S. 33
APPEAL FROM THE COURT OF CLAIMS
Syllabus
Where two sections of the Revised Statutes, when taken together, are not free from ambiguity and cannot be harmoniously applied, recourse may be had to legislation prior to the Revised Statutes from which the provisions of those sections were drawn in order to arrive at the correct meaning. Hamilton v. Rathbone, 175 U.S. 418, and Bate Refrigerating Co. v. Sulzberger, 157 U.S. 1, distinguished. Sections 5214 and 3411, Rev.Stat., cannot be so construed together, and effect given to both, as to leave a national bank liable to the duty imposed by § 5214 and yet entitle it to the exemption provided by § 3411 under the contingency stated therein.
The provisions in § 3411, Rev.Stat., exempting banks from taxation on circulation, does not relate to national banks, but to state banks only.
One of the public policies of the National Bank Act was to secure the public credit and encourage the issue of notes to circulate as currency founded upon United States bonds, and § 3411 will not be construed as intending to exempt those national banks that allowed their circulation to fall below five percent of their capital from the taxation provided by § 5214 to create a fund to bear the burden common to all national banks for engraving and printing the notes. A uniform construction ever since its enactment for a long period, in this case over thirty-five years, engenders doubt of a new and different construction.
42 Ct.Cl. 6 affirmed.
The facts are stated in the opinion.
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Chicago: U.S. Supreme Court, "Syllabus," Merchants National Bank v. United States, 214 U.S. 33 (1909) in 214 U.S. 33 214 U.S. 34–214 U.S. 38. Original Sources, accessed November 25, 2024, http://originalsources.com/Document.aspx?DocID=M353LNXIW3J3Z69.
MLA: U.S. Supreme Court. "Syllabus." Merchants National Bank v. United States, 214 U.S. 33 (1909), in 214 U.S. 33, pp. 214 U.S. 34–214 U.S. 38. Original Sources. 25 Nov. 2024. http://originalsources.com/Document.aspx?DocID=M353LNXIW3J3Z69.
Harvard: U.S. Supreme Court, 'Syllabus' in Merchants National Bank v. United States, 214 U.S. 33 (1909). cited in 1909, 214 U.S. 33, pp.214 U.S. 34–214 U.S. 38. Original Sources, retrieved 25 November 2024, from http://originalsources.com/Document.aspx?DocID=M353LNXIW3J3Z69.
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