Cash Tax Refunds

26 Pa. D. & C.2d 377
CourtPennsylvania Department of Justice
DecidedFebruary 1, 1962
StatusPublished

This text of 26 Pa. D. & C.2d 377 (Cash Tax Refunds) is published on Counsel Stack Legal Research, covering Pennsylvania Department of Justice primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cash Tax Refunds, 26 Pa. D. & C.2d 377 (Pa. 1962).

Opinion

George W. Keitel,

We have your request to be advised as to whether the amendment of November 7,1961, to article III, sec. 16, [378]*378of the Pennsylvania Constitution is self-executing or requires enabling legislation.

As amended, article III, sec. 16, of the Pennsylvania Constitution now reads as follows:

“No money shall be paid out of the treasury, except on appropriations made by law and on warrant issued by the proper officer; but cash refunds of taxes, licenses, fees and other charges paid or collected, but not legally due, may be paid as provided by law, without appropriation from the fund into which they were paid, on warrant of the proper officer .” (Italics supplied.)

The italicized portion represents the language added by the 1961 amendment.

The rule as to self-executing constitutional provisions is stated thus in Davis v. Burke, 179 U. S. 399, 403, 21 S. Ct. 210, 45 L. Ed. 249 (1900), quoted with approval in O’Neill v. White, 343 Pa. 96, 100, 22 A. 2d 25, 27, (1941) :

“ ‘Where a constitutional provision is complete in itself it needs no further legislation to put it in force. When it lays down certain general principles, as to enact laws upon a certain subject, or for the incorporation of cities of certain population, or for uniform laws upon the subject of taxation, it may need more specific legislation to make it operative. In other words, it is self-executing only so far as it is susceptible of execution.’ ”

The Supreme Court of Pennsylvania has determined whether a variety of constitutional provisions were self-executing. Those decisions are summarized in 7 P. L. Encyc. 203 “Constitutional Law,” §14, as follows:

“In specific cases, various provisions of the Constitution relating to such matters as preservation of powers in the people, the removal of appointive officers, city sinking funds, prohibition of multiple office hold[379]*379ing, and the abolition and transfer of county office functions in Philadelphia, have been held to be self-executing, while in other cases provisions relating to matters involving vacancies in elective office, judicial districts, magistrates’ courts, vacancies in the Supreme Court, trial of civil cases without a jury, uniformity of taxation, payment of county officers’ salaries, submission of charters to voters, methods of voting for corporate directors, issuance of corporate stocks or bonds, and the taking of private property for public use, have been held to be not self-executing.”

The 1961 amendment to article III, sec. 16, can be construed as self-executing only if no ancillary legislation is necessary to the enjoyment of the right to receive a cash refund without the appropriation of moneys therefor.

At present, section 503(a) of The Fiscal Code of April 9, 1929, P. L. 343, 72 PS §503, authorizes the Board of Finance and Revenue to make such refunds “. . . out of any appropriation or appropriations made for the purpose,” or to credit the account of the party entitled to the refund. The constitutional amendment will now permit the legislature to amend section 503 of The Fiscal Code so as to permit cash refunds out of the fund into which the taxes, licenses, fees or other charges for which refund is being sought were originally paid.

There appear to be at least four reasons why the 1961 amendment to article III, sec. 16, should be construed as not being self-executing without the need for further legislation:

1. This Section Deals With Limitations on Legislative Power.

The amendment is, in effect, an exception to a prohibition against the disbursement of funds without appropriations. This deprives the amendment of an [380]*380initial positive effect. It merely describes- one situation where it will not be unconstitutional to disburse State moneys without a specific appropriation.

In Commonwealth ex rel. Griest, 196 Pa. 396, 408, 409, 46 Atl. 505, 507 (1900), the court construed in detail the significance of article III of the Pennsylvania Constitution, saying, in part:

“. . . The 3d article of the constitution is confined exclusively to the subject of legislation. It is entitled ‘Of legislation’ and. only purports to be an authorization and limitation of the legislation of the commonwealth. It prescribes the manner in which the business of making laws must be conducted, and the subjects with reference to which it may, and may not, be exercised. . . . The remaining sections [from the 9th] down to the 26th, contain prohibitive limitations as to some subjects and directory provisions as to others, but all of an exclusively legislative character. . . . the entire article is confined exclusively to the subject of legislation, that is the actual exercise of the lawmaking power of the commonwealth in its usual and ordinary acceptation. . . .” (Italics supplied.)

Since the provisions in article III are of an exclusively legislative character, it is presumed that section 16 deals primarily with legislative power, and not with the creation of individual rights.

2. The Language Is Permissive Rather Than Mandatory

The constitutional amendment uses the word “may” instead of “shall.” This indicates a permissive rather than a mandatory provision. Unless the context requires otherwise, the word “may” is construed to be permissive rather than mandatory.

In Commonwealth v. A. M. Byers Co., 346 Pa. 555, 561, 31 A. 2d 530, 532 (1943), the court said:

“. . . The word ‘may’ clearly implies discretion[381]*381ary power. The language is permissive, rather than mandatory. ...”

In Mikell v. Philadelphia School District, 359 Pa. 113, 122, 58 A. 2d 339, 344 (1948), the court said:

“. . . The legal distinction between directory and mandatory laws is as applicable to fundamental as it is to statutory law: ...”

Since, as noted supra, article III of the Pennsylvania Constitution deals with limitations upon the. legislature, the use of the word “may” in the amendment to section 16 indicates that the legislature has now been authorized to permit cash refunds without the necessity of making appropriations. The legislature having obtained such permission is now free to adopt legislation that expands the rights to obtain cash refunds.

3. Legislature Has Plenary Power Over Refunds

Refunds of taxes and license fees are matters of legislative grace, and not of constitutional right, and “ The Commonwealth is not obliged to entertain claims against it at all . . : Land Holding Corporation v. Board of Finance and Revenue, 388 Pa. 61, 67, 130 A. 2d 700 (1957). Failure to comply with the express conditions on the right to obtain a refund results as an absolute bar to the right itself: Federal Deposit Insurance Corporation v. Board of Finance and Revenue, 368 Pa. 463, 470, 84 A. 2d 495 (1951). The statutory limitation upon any action by the State in consenting to be sued must be strictly construed: Box Office Pictures, Inc., v. Board of Finance and Revenue, 402 Pa. 511, 166 A. 2d 656 (1961).

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Related

Davis v. Burke
179 U.S. 399 (Supreme Court, 1900)
O'Neill v. White
22 A.2d 25 (Supreme Court of Pennsylvania, 1941)
Commonwealth v. A. M. Byers Co.
31 A.2d 530 (Supreme Court of Pennsylvania, 1943)
Mikell v. Philadelphia School District
58 A.2d 339 (Supreme Court of Pennsylvania, 1948)
Wattson v. Chester & Delaware River Railroad
83 Pa. 254 (Supreme Court of Pennsylvania, 1877)
Commonwealth v. Griest
46 A. 505 (Supreme Court of Pennsylvania, 1900)
Guenthoer's Estate
83 A. 617 (Supreme Court of Pennsylvania, 1912)
Federal Deposit Insurance v. Board of Finance & Revenue of Commonwealth
84 A.2d 495 (Supreme Court of Pennsylvania, 1951)
Land Holding Corp. v. Board of Finance & Revenue
130 A.2d 700 (Supreme Court of Pennsylvania, 1957)
Box Office Pictures, Inc. v. Board of Finance & Revenue
166 A.2d 656 (Supreme Court of Pennsylvania, 1961)
Bell v. Farwell
42 L.R.A. 804 (Illinois Supreme Court, 1898)

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26 Pa. D. & C.2d 377, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cash-tax-refunds-padeptjust-1962.