G Cite
cited 9× by 4 distinct cases, 2012–2026 · 2 courts ·
…where the language relied upon to bring a particular person within a tax law is ambiguous or is reasonably susceptible of an interpretation that will exclude such person, then the person will be excluded, any substantial doubt being resolved in his favor.
at p. 509
⚠ not in text
Treatment trajectory · 1937 → 2026 · click a year to view as-of
1937
1981
2026
Top citers, strongest first. 5 distinct citers.
How cited ↗
examined
Cited as authority (verbatim quote)
Amazon Services v. SCDOR
(2×)
also: Cited as authority (quoted)
where the language relied upon to bring a particular person within a tax law is ambiguous or is reasonably susceptible of an interpretation that will exclude such person, then the person will be excluded.
examined
Cited as authority (verbatim quote)
Rent-A-Center E., Inc. v. S.C. Dep't of Revenue
(4×)
also: Cited as authority (quoted), Cited "see"
where the language relied upon to bring a particular person within a tax law is ambiguous or is reasonably susceptible of an interpretation that will exclude such person, then the person will be excluded, any substantial doubt being resolved in his favor.
examined
Cited as authority (verbatim quote)
Alltel Communications, Inc. v. South Carolina Department of Revenue
(2×)
also: Cited as authority (quoted)
where the language relied upon to bring a particular person within a tax law is ambiguous or is reasonably susceptible of an interpretation that will exclude such person, then the person will be excluded, any substantial doubt being resolved in his favor.
cited
Cited as authority (rule)
Amazon Services, LLC v. SCDOR
Tax Comm'n, 182 S.C. 72, 76 , 188 S.E. 508, 509-10 (1936)).
cited
Cited as authority (rule)
Books-A-Million, Inc. v. South Carolina Department of Revenue
Tax Comm'n, 182 S.C. 72, 76 , 188 S.E. 508, 510 (1936) (quoting United States v. Merriam, 263 U.S. 179, 187-88 (1923)).
Retrieving the full opinion text from the archive…
Cooper River Bridge, Inc.,
v.
South Carolina Tax Comm. Et Al.
v.
South Carolina Tax Comm. Et Al.
Supreme Court of South Carolina.
Dec 1, 1936.
Messrs. John M. Daniel, Attorney General, and Claude K. Wingate , for appellants, cite: Where road dedicated to public use: 143 S.C. 104 ; 141 S.E., 180 ; 124 S.C. 302 ; 117 S.E., 599 ; 133 S.C. 139 ; 130 S.E., 514 . Construction of statute: 166 S.C. 536 ; 59 S.C. 225 ; 37 S.E., 818 ; 83 S.C. 566 ; 65 S.E., 825 ; 36 Cyc., 1120.
Messrs. Mitchell Horlbeck , for respondent, cite: Construction of statute: 1 N. McC., 460; 19 C.J., 1255; 166 S.C. 536 ; 142 S.C. 466 ; 83 S.C. 566 ; 104 S.C. 217 ; 263 U.S. 244 ; 127 S.C. 473 ; 139 S.C. 107 ; 128 S.C. 14 ; 171 S.C. 441 ; 139 S.C. 108 ; 127 S.C. 482 ; 128 S.C. 365 . Collection of toll: 51 C.J., 1; 158 U.S. 435 .
Fishburne, Stabler, Messrs, Bonham, Baker, Gaston.
can only refer to such corporations as are embraced in the statutory definition so adopted
The opinion of the Court was delivered by
Mr. Justice Fishburne.The facts and issues involved in this appeal are fully stated in the decree of his Honor, Judge Grimball, which wil be reported. We are in accord with the conclusions reached by him and with his disposition of the case.
[*81] Accordingly, the exceptions thereto are overruled, and the judgment of the lower Court is affirmed.
Mr. Chief Justice Stabler and Messrs Justices Bonham and Baker and Mr. Acting Associate Justice A. L. Gaston concur.