Yazoo & Mississippi Valley Railroad v. Thomas

Citations

• 132 U.S. 174
• 10 S. Ct. 68
• 33 L. Ed. 302
• 1889 U.S. LEXIS 1858

Syllabus

<p>This court has jurisdiction to review, on writ of error, a decision of the highest court of a State, in which it is decided that a provision in a tax act of the State that it shall not apply to railroad corporations exempted from taxation by their charters is not applicable to a particular corporation, party to the suit, although its charter contains a provision respecting exemption from taxation.</p> <p>Exemptions from taxation, being in derogation of the sovereign authority and of common right, are not to be extended beyond the express requirements of the language used, when most rigidly construed.</p> <p>The appellant’s charter provided that it should “ be exempt from taxation for a term of twenty years from the completion of said railroad to the Mississippi River, but not to extend beyond twenty-five years from the date of the approval of this act: ” Held, that the exemption was intended to commence from and after the completion of a railroad to the Mississippi River', and was to continue thereafter for twenty years if the road was completed to the river in five years from the date of the approval of the act, but liable to be diminished by whatever time beyond five year’s was consumed by the completion of the road to the river.</p> <p>The preamble to a statute is no part of it, and cannot enlarge or confer powers, or control the words of the act unless they are doubtful or ambiguous.</p> <p>Vicksburg, Shreveport & Pacific Railway Co. v. Dennis, 116 U. S. 665, approved and applied.</p>