HONOLULU RAPID TRANSIT AND LAND COMPANY
v.
WILDER, ASSESSOR
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Honolulu Rapid Transit and Land Company sought review of an income tax assessment of $588.20, claiming it was entitled to deduct certain amounts from its gross income under its charter. The Supreme Court dismissed the writ because the tax amount was too small to meet the jurisdictional threshold for Supreme Court review under the relevant statute, and the company had failed to properly raise any federal constitutional question before the assignment of error in the Supreme Court.
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Mr. Justice Holmes delivered the opinion of the court.
This case is intended to bring up a question of deductions from gross income in assessing the income tax of the appellant, as well as that of the liability'of the plaintiff in error to the tax. The liability to taxes not mentioned in the charter has. been disposed of by the preceding case. As to the former question, the plaintiff in error says that it has no net income liable to taxation. But the whole tax assessed was $588.20, and therefore the case cannot be brought here under the act of March 3, 1905, c. 1465, § 3, 33 Stat.
1035. On the other hand, the record does not show that any Federal question was raised or suggested before the assignment of error in this court, and therefore the plaintiff in error has no standing under the act of April 30, 1900, c. 339, § 86, 31 Stát.
141. It is true that in the decision of the Tax Appeal Court it is said that the appellant claims under § 17 of its charter a right to charge certain amounts against income. But it does not appear there or elsewhere that the appellant set up that the charter was a statute of the United States, or that it relied upon Article I, § 10, or any other clause of the Constitution of the United States.
Writ dismissed.
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Toyota v. Territory of Hawaii, 226 U.S. 184 (U.S. 1912)…y v. Brown, 187 U. S. 308, 309; Notley v. Brown, 208 U. S. 429, 440. In view of the amount involved, the case cannot in any view come within the amendment made by the act of March 3, 1905, c. 1465, § 3, 33 Stat. 1035; Honolulu Transit Co. v. Wilder, 211 U. S. 144. The remaining contention, urged -in various forms by-the assignments of error, comes to the single point that the-statute created an arbitrary classification. . It cannot be said, however, that there was no reasonable basis for á distinction betwe…