U.S. Supreme Court HELVERING v. STOCKHOLMS ENSKILDA BANK, 293 U.S. 84 (1934)

[Page 293 U.S. 84, 94]

nection with the context, the general purposes of the statute in which it is found, the occasion and circumstances of its use, and other appropriate tests for the ascertainment of the legislative will. Compare Rein v. Lane, L.R. 2 Q.B. Cases 144, 151. The intention being thus disclosed, it is enough that the word or clause is reasonably susceptible of a meaning consonant therewith, whatever might be its meaning in another and different connection. We are not at liberty to reject the meaning so established and adopt another lying outside the intention of the Legislature, simply because the latter would release the taxpayer or bear less heavily against him. To do so would be not to resolve a doubt in his favor, but to say that the statute does not mean what it means. 'The rule of strict construction is not violated by permitting the words of a statute to have their full meaning, or the more extended of two meanings. The words are not to be bent one way or the other, but to be taken in the sense which will best manifest the legislative intent. United States v. Hartwell, 6 Wall. 385, 396; United States v. Corbett, 215 U.S. 233, 242, 30 S.Ct. 81.' Sacramento Nav. Co. v. Salz, 273 U.S. 326, 329, 47 S.Ct. 368, 369. The rule of strict construction applies to penal laws, but such laws are not to be construed so strictly as to defeat the obvious intention of the Legislature; or so applied as to narrow the words of the statute to the exclusion of cases which those words, in the sense that the Legislature has obviously used them, would comprehend. United States v. Wiltberger, 5 Wheat. 76, 95. That view, expressed by Chief Justice Marshall, has since been frequently followed by this court. See, for example, American Fur Company v. United States, 2 Pet. 358, 367; United States v. Morris, 14 Pet. 464, 475; United States v. Hartwell, supra, pages 395, 396 of 6 Wall.; Donnelley v. United States, 276 U.S. 505, 512, 48 S.Ct. 400.

Judgment reversed. Footnotes

Footnote 1 As, for example, it did in the Act of March 3, 1919, 4, c. 100, 40 Stat. 1309, 1311 (31 USCA 750).