
    THE TIDE WATER OIL COMPANY v. THE UNITED STATES.
    [31 C. Cls. R., 90;
    
    
      171 U. S. R.]
    
      On the claimants’ Appeal.
    
    The claimants import box shooks manufactured in Canada. They come in bundles, planed, and of the required lengths and widths, needing only to be nailed together and trimmed, when defective in length or width, to make a box. The claimants export the boxes and demand a drawback.
    The court below decides:
    1. The Revised Statutes (§ 3019) allow a drawback on “all articles wholly manufactured of materials imported, on which duties have been paid.” Boxes made of shooks manufactured in Canada, planed, and of the requisite length and width, so that nothing remains to be done except nail the shooks together and trim the boxes where the shooks are defective in length or width, are not a domestic manufacture within the intent of the statute.
    2. The intent of the statute is that the manufacture be within the United States; that the exported article shall not have been partially manufactured elsewhere.
    3. The mere fastening together of imported material which was designed and shaped for that specific use abroad does not constitute a manufacture.
    4. Material is matter intended to be used in the creation of a mechanical structure. Manufacture is a transformation of the material used into a new and different article.
    5. The purpose of the statute was not to increase revenue or encourage • an exjjort trade, but to foster domestic manufactures.
    6. Shooks are classed by the Revised Statutes (§2502) with casks, barrels, and packing boxes, and are dutiable at the same rate. If imported as boxes, the rate of duty would have been the same.
    7. Such a statutory classification indicates that shooks were regarded by Congress as a finished or manufactured material.
    The decision of the court below is affirmed on the same grounds.
    May 31, 1898.
   Mr. Justice JBrown

delivered the opinion of the Supreme Court  