It is apparent that courts, in construing revenue laws, will give terms a wider meaning than when construing a penal statute, or a statutory or constitutional prohibition, when it is sought to bring an individual within the terms of the statute. The business of banking, under the license tax law, consists, among other things, in having a place of business where money is received on deposit and paid out upon checks or loaned upon security.1 But a so-called loan company which did not receive deposits, but loaned its own capital on realty security, and sold and guaranteed its mortgages, was not a bank under this statute.2 It seems reasonably certain that a place of business performing either the banking function of deposit or that of issue would be considered a bank. The same cannot safely be said of a business confined wholly to discounting. One court has held that a banker can be compelled to pay a license on the ground that he is a " moneychanger." 3 This last decision is historically correct, because originally the sole business of the mediaeval prototype of the modern banker was exchanging the different varieties of money.4 tow, 6 Cow. 290, and Curtis v. Leav-itt, 15 N. Y. 9, 56.

7Corwin v. Insurance Co., 14 Ohio, 6.

8 Commonwealth v. Sponsler, 16 Pa. Co. Ct. R. 116.

1 Warren v. Shook, 91 U. S. 704.

2Selden v. Equitable Trust Co., 94 U. S. 419. The statute was 13 Stat, at Large, 252, carried into sec. 8407, Rev. Stat. U. S.

3 Hinckley v. Belleville, 43 I11. 183. But a savings bank authorized to deal in notes, drafts and bonds, and buy and sell bills of exchange, is not a money broker or exchange dealer under a license statute. State v. Field, 49 Mo. 270. This decision seems to be based upon the idea that it would be impossible to imprison the corporation.

4 1 Encyc. PoL Science, 232. The historical excursus in Oulton v. Sav. Inst, 17 Wall. 118, is hardly accurate.