ARTHUR, Collector, v. PASTOR & Others

Me. Justice Matthews deliyered the opinion of the" court. After stating the facts as above recited, he continued: The construction of the statute and the rule of computation, adopted by the .collector, proceed upon the supposition that the rate of duty to be charged’ and collected upon washed wool is to be double that charged and collected upon the same weight and value of unwashed wool. Hence, because 3,294 pounds of unwashed wool would.be chargeable with'a duty of tem-cents per pound, and eleven pep cent, of its appraised value as unwashed wool, it is found that the same weight of .washed wool would be chargeable with twenty cents per pound, and twenty-two per cent, of its appraised value as washed wool. The error in this calculation clearly.is in. assuming that the same number of pounds of unwashed wool would, be worth as much as washed wool, a supposition which is inconsistent with the fact as admitted, and with the evident meaning., of the law. The language of the act of Congress- is too plain to admit of doubt. It declares that the duty upon a given quan *142 tity of washed wool shall he twice the amount of duty “ to which it would be subjected if imported unwashed.” By the terms of the comparison the weight is supposed to be the same in both cases — in the case, as actually presented, a quantity of wool weighing 3,294 pounds. Hence the duty, so far as determined by weight, is calculated upon the same number of pounds, being eleven cents a pound for the unwashed wool, and twenty-two cents per pound for the washed wool. But when the ad valorem duty is to be determined, the relative values necessarily determine its amount; and; as 3,294 pounds of unwashed wool is to be appraised at $813.50, while the same weight of washed wool would be twice that sum, or $1,627, it follows, that the duty on the latter is to be double that which the law imposes upon the former, namely, twenty-two per cent, of $813.50, which is equal to $178.97, and not ■ twenty-two per cent, on $1,627, equal to $357.94, as charged by the collector. If the rule adopted by him should prevail, the amount of the ad valorem duty collected upon equal weights of unwashed and of washed wool, would be four times as great upon the latter as upon the former, for not only is the rate of duty doubled, but it is assessed upon double the. value- of the unwashed wool.' But the statute expressly limits the duty in the case of washed wool to double the amount to which it would be subjected if imported unwashed. It is admitted in argument that the letter of the law justifies, if it does not require this conclusion; but it is urged that the meaning of the statute requires the construction which would impose rates of duty upon washed wool double those imposed upon unwashed, calculated upon the weight and value of each separately considered. And this contention ishhaintained upon the argument that the contrary reading of the statute implies that Congress has made the appraised value of wool in its unwashed state the standard for determining the amount of ad valorem duty to be collected upon washed wool, which, it is insisted upon the argument, ab inconvenienti, is not admissible. But this is, not by implication merely, but expressly what the act declares; and; any fancied or real objections to such a standard cannot affect the obvious meaning of the law. It is *143 obvious, however, that, the natural division of wools into the grades of unwashed, 'washed, and scoured,, carried' into 'the act as the ground of difference in the amount of duties to be assessed accordingly, fully explains the .intention of Congress to tax the wool itself uniformly by varying the amount of' duty-according to the degree to which a. given quantity has been freed, by processes of cleansing from the dirt and foreign matter with which, in its unwashed state, it is usually found. There is no error in the record, and .the judgment is Affirmed,