Memphis & Little Rock Railroad Co. (as reorganized) v. Berry et al.
construction consistent with the reservation of the power. If a doubt arise as to the intent of the legislature, that doubt must be solved in favor of the State."
In Ohio Life Insurance Trust & Co. v. Debolt, 16 How. U.S., 435. "The grant of privileges to a corporation are strictly construed against the corporation, and in favor of the public. Nothing passes but what is granted in clear and explicit terms, and neither the right of taxation, nor any other power of sovereignty which the community have an interest in preserving undiminished, will be held by the court to be surrendered unless the intention to surrender is manifested by words too plain to be mistaken."
Hoge v. Railroad Co., 99 U.S., 355. "The power of the legislature of a State to exempt particular property of individuals, or of corporations, from taxation, not merely during the period of its own existence, but so as to be beyond the control of the taxing powers of succeeding legislatures, has been asserted in several cases by this court, although against this doctrine, there have been earnest protests by individual judges."
"But, though this power has been recognized, it is accompanied with the qualification that the intention of the legislature to grant the immunity must be clear beyond a reasonable doubt. It cannot be inferred from ambiguous terms or uncertain phrases. The power of taxation is an attribute of sovereignty, and is essential to every independent government. Stripped of this power, it must perish. Whoever therefore claims its surrender must show it in language that will admit of no other reasonable construction."
But it is needless to multiply authorities on this point to show how far the courts have gone in emphasizing the restrictions and limitations thrown around this sort of grant. We add only from Fertilizing Company v. Hyde Park, 97 U.S., 666. "The rule of construction in this class of cases is that it shall be most strongly against the corpora-
