Gallatin Farmers Co. v. Shannon

Mr. Justice Morris:

I dissent. The taxes imposed that give rise to this controversy were imposed pursuant to the provisions of the Corporation License Tax Act, Chapter 205, comprising sections 2296 to 2304 of the Revised Codes. It is a special Act relating to that particular subject, and provides no such exemption as that claimed by the plaintiff and allowed by the majority in reversing the district court. Chapter 204, comprising sections 2295.1 to 2295.34, inclusive, is the Income Tax Act, and that Act carries an express exemption by which such concerns as the plaintiff are exempted from…