opinion: DAMERON v. BRODHEAD, MANAGER OF REVENUE & EX-OFFICIO TREASURER OF THE CITY & COUNTY OF DENVER.
  No. 302.
  Argued February 4, 1953.
  Decided April 6, 1953.
  Philip Elman argued the cause for petitioner. With him on the brief were Solicitor General Cummings, Assistant Attorney General Lyon, Ellis N. Slack and Berryman Green.
  Leonard M. Campbell argued the cause for respondent. With him on the brief was John C. Banks.
  Mr. Justice Reed
  delivered the opinion of the Court.
  The facts here are simple and undisputed. Petitioner is a commissioned officer of the United States Air Force. He was assigned to duty at Lowry Field, near Denver, Colorado, in 1948 and, throughout that year, resided in a privately rented apartment in that city. Respondent, acting Manager of Revenue and ex-officio Treasurer and Assessor of the City and County of Denver, assessed a tax of $23.51 on his personal property, mostly household goods in the apartment, which he valued at $460, by virtue of 4A Colorado Statutes Annotated (1935 ed.), c. 142. Petitioner paid the tax under protest, and sued to recover. His complaint pleaded as a fact that he, “during the whole of the calendar year -1948, and for many years prior thereto, was, and at the present time is, a citizen and a resident of the State of Louisiana, domiciled in the Town of Port Allen, in the Parish of West Baton Rouge, in the State of Louisiana, and remains a domiciliary of that town, parish, and state, and a citizen and resident of said state, in which during all of the period of time pertinent hereto the plaintiff was and is a qualified voter.” He claimed that § 514 of the Soldiers’ and Sailors’ Civil Relief Act, 54 Stat. 1186, as amended, 56 Stat. 777, 58 Stat. 722, 50 TJ. S. C. App. §§ 501, 574, therefore forbade imposition of the Colorado tax. Respondent moved to dismiss, argument was had and the trial court entered judgment for petitioner. The Colorado Supreme Court, on appeal, reversed. Cass v. Dameron, 125 Colo. 477, 244 P. 2d 1082. It held that the purpose of the statute was to prevent multiple taxation of military personnel, but that since Louisiana had not taxed petitioner’s personal property, Colorado was free to do so. Our grant of certiorari rested on 28 U. S. C. § 1257 (3). 344 U. S. 891.
  Section 514 of the Act was added, in large part, in 1942. It then provided essentially that:
  “For the purposes of taxation in respect of any person, or of his property, income, or gross income, by any State, Territory, possession, or political subdivision of any of the foregoing, or by the District of Columbia, such person shall not be deemed to have lost a residence or domicile in any State, Territory, possession, or political subdivision of any of the foregoing, or in the District of Columbia, solely by reason of being absent therefrom in compliance with military or naval orders, or to have acquired a residence or domicile in, or to have become resident in or a resident of, any other State, Territory, possession, or political subdivision of any of the foregoing, or the District of Columbia, while, and solely by reason of being, so absent.”
  The 1944 Amendment thereto, which is crucial here, first concerned personal property taxes. It stated:
  “personal property shall not be deemed to be located or present in or to have a situs for taxation in such State, Territory, possession, or political subdivision, or district.”
  It also interpolated “personal” in the second line of §514(1). 58 Stat. 722.
  Respondent’s argument that the statute in this form cannot affect Colorado’s attempt to tax petitioner is twofold — either it does not apply or is unconstitutional.
  The constitutionality of federal legislation exempting servicemen from the substantial burdens of seriate taxation by the states in which they may be required to be present by virtue of their service, cannot be doubted. Generally similar relief has often been accorded other types of federal operations or functions. And we have upheld the validity of such enactments, even when they reach beyond the activities of federal agencies and corporations to private parties who have seen fit to contract to carry on functions of the Federal Government. Carson v. Roane-Anderson Co., 342 U. S. 232, and cases cited; cf. James v. Dravo Contracting Co., 302 U. S. 134, 160-161.
  Nor do we see any distinction between those cases and this. Surely, respondent may not rely on the fact that petitioner here is not a business contractor. He is not the less engaged in a function of the Federal Government merely because his relationship is not entirely economic. We have, in fact, generally recognized the especial burdens of required service with the armed forces in discussing the compensating benefits Congress provides. Le Maistre v. Leffers, 333 U. S. 1; Boone v. Lightner, 319 U. S. 561. Cf. Board of Commissioners v. Seber, 318 U. S. 705. Petitioner’s duties are directly related to an activity which the Constitution delegated to the National Government, that “to declare War,” U. S. Const., Art. I, § 8, cl. 11, and “to raise and support Armies.” Ibid., cl. 12. Since this is so, congressional exercise of a “necessary and proper” supplementary power such as this statute must be upheld. Pittman v. Home Owners’ Corp., 308 U. S. 21, 32-33; Federal Land Bank v. Bismarck Co., 314 U. S. 95, 102-104. Carson v. Roane-Anderson Co., supra, at 234. What has been said in no way affects the reserved powers of the states to tax. For this statute merely states that the taxable domicile of servicemen shall not be changed by military assignments. This we think is within the federal power.
  We turn, then, to the interpretation of the statute within the factual confines of this particular case. Respondent’s theory here also has no merit. It is based on the statements of the legislative history that, for instance, the provision was “designed to prevent multiple State taxation.” H. R. Rep. No. 2198, 77th Cong., 2d Sess., p. 6. The short answer to the argument that it therefore only applies where multiple taxation is a real possibility is that the plain words of the statute do not say so. In fact, they are much broader: “personal property shall not be deemed to be located or present in or to have a situs for taxation” in the state of temporary presence in any case. There is no suggestion that the state of original residence must have imposed a property tax. Since the language of the section does not establish a condition to its application, we would not be justified in doing so. For we are shown nothing that indicates that a straightforward application of the language as written would violate or affect the clear purpose of the enactment. See United States v. Public Utilities Comm’n, ante, p. 295, decided today, and cases cited. In fact, though the evils of potential multiple taxation may have given rise to this provision, Congress appears to have chosen the broader technique of the statute carefully, freeing servicemen from both income and property taxes imposed by any state by virtue of their presence there as a result of military orders. It saved the sole right of taxation to the state of original residence whether or not that state exercised the right. Congress, manifestly, thought that compulsory presence in a state should not alter the benefits and burdens of our system of dual federalism during service with the armed forces.
  For similar reasons, we reject the argument that the word “deemed” as used implies a rebuttable presumption so as to permit taxation by the state of temporary presence in some cases. Such a construction would nullify the statute. For in every case, the absence of the property from the state of the serviceman’s temporary presence would be a fiction, rebuttable by further evidence.
  Reversed.
  This statute, in standard form, provides that “[a]ll personal property within this state on March first at twelve o’clock meridian in the then current year shall be listed and assessed,” § 72, and that the taxes so assessed “shall be and remain a perpetual lien upon the property so levied upon,” § 197 (a).
  See also Hearings, House Committee on Military Affairs on H. R. 7029, 77th Cong., 2d Sess.; S. Rep. No. 959, 78th Cong., 2d Sess.; H. R. Rep. No. 1514, 78th Cong., 2d Sess.
  Hearings, note 2, supra, p. 28.
instruction: What follows is an opinion from the Supreme Court of the United States. Your task is to determine whether the decision of the court whose decision the Supreme Court reviewed was itself liberal or conservative. In the context of issues pertaining to criminal procedure, civil rights, First Amendment, due process, privacy, and attorneys, consider liberal to be pro-person accused or convicted of crime, or denied a jury trial, pro-civil liberties or civil rights claimant, especially those exercising less protected civil rights (e.g., homosexuality), pro-child or juvenile, pro-indigent pro-Indian, pro-affirmative action, pro-neutrality in establishment clause cases, pro-female in abortion, pro-underdog, anti-slavery, incorporation of foreign territories anti-government in the context of due process, except for takings clause cases where a pro-government, anti-owner vote is considered liberal except in criminal forfeiture cases or those where the taking is pro-business violation of due process by exercising jurisdiction over nonresident, pro-attorney or governmental official in non-liability cases, pro-accountability and/or anti-corruption in campaign spending pro-privacy vis-a-vis the 1st Amendment where the privacy invaded is that of mental incompetents, pro-disclosure in Freedom of Information Act issues except for employment and student records. In the context of issues pertaining to unions and economic activity, consider liberal to be pro-union except in union antitrust where liberal = pro-competition, pro-government, anti-business anti-employer, pro-competition, pro-injured person, pro-indigent, pro-small business vis-a-vis large business pro-state/anti-business in state tax cases, pro-debtor, pro-bankrupt, pro-Indian, pro-environmental protection, pro-economic underdog pro-consumer, pro-accountability in governmental corruption, pro-original grantee, purchaser, or occupant in state and territorial land claims anti-union member or employee vis-a-vis union, anti-union in union antitrust, anti-union in union or closed shop, pro-trial in arbitration. In the context of issues pertaining to judicial power, consider liberal to be pro-exercise of judicial power, pro-judicial "activism", pro-judicial review of administrative action. In the context of issues pertaining to federalism, consider liberal to be pro-federal power, pro-executive power in executive/congressional disputes, anti-state. In the context of issues pertaining to federal taxation, consider liberal to be pro-United States and conservative pro-taxpayer. In miscellaneous, consider conservative the incorporation of foreign territories and executive authority vis-a-vis congress or the states or judcial authority vis-a-vis state or federal legislative authority, and consider liberal legislative veto. The lower court's decision direction is unspecifiable if the manner in which the Supreme Court took jurisdiction is original or certification; or if the direction of the Supreme Court's decision is unspecifiable and the main issue pertains to private law or interstate relations