By this action, General Petroleum Corporation of California, a corporation, seeks to recover the sum of $6194.48 paid by its predecessor, General Pipe Line Company of California, between June 21, 1932, and December 31, 1934, as a tax on casing-head or natural gasoline transported by pipe line.

The payment was made under the Revenue Act of 1932, which imposed a tax “upon all transportation of crude petroleum and liquid products thereof by pipe line originating on or after the fifteenth day after the date of the enactment of this Act and before July 1, 1935.” Sec. 731(a), Revenue Act of 1932, 26 U.S.C.A. note following section 1481.

The question we are to decide is whether casing-head or natural gasoline is a product of crude petroleum.

Words used in legislative enactments are to be given their natural significance. The sense to be attributed to them is that of the everyday speech of men. If words refer to articles of trade, they are to be interpreted in the sense in which they are understood by those in the trade. See Two Hundred Chests of Tea, Smith, Claimant, 1824, 9 Wheat. 430 , 6 L.Ed. 128 ; Maillard v. Lawrence, 1853, 16 How. 251, 261 , 14 L.Ed. 925 ; American Net & Twine Company v. Worthington, 1891, 141 U.S. 468 , 12 S.Ct. 55 , 35 L.Ed. 821 ; Robertson v. Salomon, 1889, 130 U.S. 412, 413 , 9 S.Ct. 559 , 32 L.Ed. 995 ; Burke v. Southern Pacific R. Co., 1914, 234 U.S. 669 , 34 S.Ct. 907 , 58 L.Ed. 1527 ; Takao Ozawa v. United States, 1922, 260 U.S. 178, 194 , 43 S.Ct. 65, 67 , 67 L.Ed. 199 ; United States v. Bhagat Singh Thind, 1923, 261 U.S. 204, 209 , 43 S.Ct. 338, 339 , 67 L.Ed. 616 ; City of Lincoln v. Ricketts, 1936, 297 U.S. 373, 376 , 56 S.Ct. 507, 509 , 80 L.Ed. 724 .

These principles are a recognition of the democratic origin of language. Words do not become a part of language unless they get themselves accepted as a part of the everyday speech of mán. Technical words, of course, are given the technical significance which their acceptance by a particular craft or group has conferred upon them.

The difficulty which confronts us here is traceable to the absence of agreement as to the meaning of the words “crude petroleum” and as to the derivation of easing-head gasoline.

Petroleum is a mineral consisting essentially of a complex mixture of hydrocarbons. Burke v. Southern Pacific R. Co., supra; Webster’s New International Die *287 tionary, 1937. Casing-head or natural gasoline is gasoline extracted from wet gas taken from an oil well, at the casing head, in a separator or trap, as the gas leaves the well. The different kinds of gasoline contain the same hydrocarbons in various proportions. But while there is agreement as to the method of extraction, the experts disagree as to the source of the particles of gasoline found in casing-head or wet gas. Some assert that it is a product of the gas. Others assert that even when extracted from a gas well, it originates in contact with crude .oil in some subterranean stratum. We quote from the testimony of H. H. Cannon, a consulting engineer with long experience in the oil industry, who testified for the Government:

On the basis of testimony before him, Judge Williams in Twin Hills Gasoline Co. v. Bradford Oil Corp., D.C.Okl.1919, 264 F. 440, 441 , arrived at a similar conclusion : “that wet gas exists only with oil. Therefore, casing-head gas is a component of oil.’’

. Ordinarily, in instruments dealing with the products of oil, gas is used in juxtaposition with oil. So we speak ordinarily of “gas, oil and other hydrocarbon substances”. Much of the legislation concerning oil and having the aim to conserve oil uses this terminology. See Oil and Gas Conservation Law of California, Act 4916, Gen.Laws of Cal. (1937) p. 2069; Laws of Texas, Vernon’s Ann.Civ.St. Arts. 6014, 6023, 6029; Compiled Oklahoma Statutes, Secs. 7954-7963, 52 Okl.St.Ann. §§ 271-279. The words “petroleum” and “oil” are, technically, synonymous.

As the experts are in disagreement as to the relationship between gasoline, especially casing-head gasoline, and petroleum, so are the courts. Some hold that gasoline and casing-head gasoline are a part of crude oil or petroleum. See Kings County Fire Ins. Co. v. Swigert, 1882, 11 Ill.App. 590, 598 ; Poe v. Humble Oil & Refining Co., Tex.Civ.App.1926, 288 S.W. 264 ; Gilbreath v. States Oil Corp., 5 Cir., 1925, 4 F.2d 232 ; Connellee v. Magnolia Petroleum Co., Tex.Civ.App.1926, 279 S.W. 597 ; Locke v. Russell, 1915, 75 W.Va. 602 , 84 S.E. 948 ; Wemple v. Producers’ Oil Co., 1919, 145 La. 1031 , 83 So. 232 ; Livingston Oil Corp. v. Waggoner, Tex.Civ.App.1925, 273 S.W. 903 . Others hold that they are neither oil nor gas. Clymore Production Co. v. Thompson, D.C.Tex.1936, 13 F.Supp. 469 ; Hammett Oil Co. v. Gypsy Oil Co., 1921, 95 Okl. 235 , 218 P. 501 , 34 A.L.R. 275 ; Ludey v. Pure Oil Co., 1932, 157 Okl. 1 , 11 P.2d 102 ; Broswood Oil Co. v. Sand Springs Home, 1936, 178 Okl. 550 , 62 P.2d 1004 ; Hopkins v. Texas Co., 10 Cir., 1933, 62 F.2d 691 ; applying Oklahoma decisions; Lone Star Gas Co. v. Harris, Tex.Civ.App.1932, 45 S.W.2d 664 .

With this divergence in the opinion of experts and of courts, the meaning of the words is to be determined in the light of the circumstances attending . their use in the particular legislation. What militates in favor of construing casing-head gasoline as a product of crude oil or petroleum is the fact that the wet gas from which it is extracted is never found except with oil. The coupling of the words “crude” and “petroleum” is, from a strictly scientific standpoint, tautological. For the word “petroleum” conveys all the meaning which the words “crude petroleum” do. Yet we find that the phrase has been used in legal instruments and in legislation and has received judicial definition. In Kings County Fire Insurance Co. v. Swigert, 11 Ill.App. 590, 598 , it is defined as follows: “Crude petroleum consists of a number of different oils, all more or less volatile, which are separated from each other by a' process of distillation, and of these, gasoline, being the most volatile, and consequently the most explosive, is the one driven off at the lowest temperature.” See 48 Corpus Juris, 1953.

When they occur, as they often do, in various tariff acts, the words are given a broad interpretation. See United States v. R. F. Downing & Co., 2 Cir., 1906, 146 *288 F. 56 ; United States v. Swan & Finch Co., 2 Cir., 1909, 169 F. 108 ; United States v. F. A. Marsily & Co., 1 Cir., 1908, 165 F. 186 .

The legislative history of the section under consideration shows that the object sought to be attained by the 1932 enactment was the taxation of gasoline transported b'y pipe line. The Revenue Acts of 1917 and 1918, 40 Stat. 300 , 315, § 500(d), 40 Stat. 1057 , 1102, § 501(d), taxed the transportation of “oil by pipe line”. Article 91 of Regulation 49, promulgated under the 1918 Act, defined the word oil as “crude petroleum and such of its products as may be transported by pipe line.” The tax on pipe line transportation was repealed in 1921. It was the object of the 1932 Act to restore it. The Act as it reached the Senate Finance Committee retained the word “oil”. It was changed in Committee to the present wording. The Committee, in its Report, stated the object of the change to be as follows:

The Conference Report on the Bill stated the object of the amendment as follows: “Sec. 731(a) Tax on transportation of oil by pipe line. Amendment No. 232: This amendment (addition of words ‘crude petroleum and liquid products thereof’ following ‘transportation of’ in first line) makes the tax under the House bill on transportation by pipe line applicable to crude petroleum and its liquid products, instead of to oil only. The House recedes.” 1932 C.C.H. Paragraph 2547-J, Special Bulletin, June 10, 1932. (Italics added.)

The' deliberate substitution of the words “crude petroleum” for “oil” indicates an intention to avoid the possible effect of decisions which had declined to consider gasoline as a derivative of oil. The use of the phrase “instead of to oil only” in the Report, shows plainly that the new terminology was to reach more products than the old one. If, as contended by the plaintiff, the words “crude petroleum” mean nothing more than “crude oil”, then the change was a useless gesture. Yet the conference committee says that they sought words of a broader meaning because they aimed to reach, by the change, products not reached by the old law. It is a peculiarity of the legislative mind in the English speaking world, as it is of its legal mind, to retain phrases which, through long usage, have acquired a definite meaning. This is especially true when a phrase has been the subject of judicial interpretation.

When words existing in a prior enactment which it is sought to revive are changed, the inference is that the old words proved inadequate for the matters which the legislation sought to reach. When added to that is the fact, expressed specifically by the legislative body, that the substitution of wording aimed to achieve a certain result, there is no room for speculation. And when the aim is obvious, the literal or even scientific meaning of a word must be disregarded in order to achieve it. See Takao Ozawa v. United States, 1922, 260 U.S. 178, 194 , 43 S.Ct. 65, 67 , 67 L.Ed. 199 . It. is conceded by the plaintiff that the tax' applied to straight-run gasoline, i. e., gasoline extracted by various processes directly from the oil. The object of the Congress being to tax gasoline in general, without any specific designation of kind, no reason appears for declining to include casing-head gasoline. Casing-head gasoline is gaspline. As the witness Cannon testified:

In view of the state of the law at the time of the enactment and its avowed purpose, I am of opinion that the Congress intended to designate hy the words “crude petroleum” all the hydrocarbon substances— whether in liquid, solid or gaseous form coming out of an oil well — and that they intended to include not only the gasoline which is mingled with the liquid substance so as to require extraction through various methods but also the natural or casing-head gasoline contained in the gas coming out at the same time as the oil and which can be captured at the casing head through separation.

There is evidence in the record that the word “petroleum” is understood in the trade to include all the hydrocarbon substances coming out of the well and to include specifically casing-head gas. We quote the following from the witness Cannon:

Alexander B. Morris, Petroleum Engineer of the Department of Internal Revenue, who testified for the Government, states:

*290 These statements lend force to the announced conclusion, derived from the legislative history of the enactment.

Tax laws are interpreted liberally in favor of the taxpayer. Doubts arising in their interpretation or application must be resolved against the taxing body. United States v. Isham, 1873, 17 Wall. 496, 504 , 21 L.Ed. 728 ; Crooks v. Harrelson, 1930, 282 U.S. 55, 61 , 51 S.Ct. 49, 51 , 75 L.Ed. 156 ; Miller v. Standard Nut Margarine Co., 1932, 284 U.S. 498, 508 , 52 S.Ct. 260, 262 , 76 L.Ed. 422 . But the doubts must be real and must spring from uncertainties apparent on the face of the taxing law. However, where, as here, the legislative history of the enactment and expert testimony in the record show the meaning intended, we would be striving for imaginary doubts, if we failed to apply it.

We conclude that casing-head gasoline, transported by pipe line, was taxable under the Revenue Act of 1932 and that the taxes paid by the plaintiff’s predecessor are not recoverable.

Judgment will be for the Government. Finding and judgment under Rule 44. Exception to the plaintiff.