8 Opinion of the Court. We agree that the social security legislation provides a method for accomplishing state and federal unemployment relief systems, integrated in plan, function, and purpose, and that sound state systems are essential to complete success of the congressional plan. But we cannot agree that Congress thereby intended in effect to amend § 3466, by making its priority provisions inapplicable to state unemployment tax claims. For while the state and federal governments were to cooperate, the underlying philosophy of the Federal Act was to keep the state and federal systems separately administered. The Act nowhere indicates a purpose to treat a state unemployment claim as the State here urges us to treat its claim-"tantamount to a claim of the United States." Furthermore, §§ 807 (c) and 905 (b) of the Federal Act, and the provisions they incorporated by reference, made applicable to social security taxes all other provisions of law relating to the assessment and collection of other taxes unless such other remedies are inconsistent with the Social Security Act. While there is no evidence that Congress in these sections had § 3466 specifically in mind, these provisions indicate that Congress intended, so far as practicable, to apply to social security taxes all of the remedies available to the Federal Government in collecting other taxes. Section 3466 provides one of these remedies. Since, as has been indicated, it is not inconsistent with either the express language or purpose of the Social Security Act, it must be applied here. Previous decisions of this Court relied on by the State do not support its contention. Those cases, insofar as they held that § 3466 did not give the United States priority over certain other types of claims, did so because later Acts were found to contain provisions plainly inconsistent with United States priority. Cook County Na tional Bank v. United States, 107 U. S. 445; United States v. Guaranty Trust Co., 280 U. S. 478. Cf. United States v. Emory, 314 U. S. 423, 431-432. We find no such inconsistency here. And "only the plainest inconsistency would warrant our finding an implied exception to the operation of so clear a command as that of § 3466." United States v. Emory, supra, 433. Affirmed. MR. JUSTICE JACKSON took no part in the consideration or decision of this case. EL DORADO OIL WORKS ET AL. v. UNITED APPEAL FROM THE DISTRICT COURT OF THE UNITED STATES FOR THE NORTHERN DISTRICT OF CALIFORNIA. No. 428. Argued January 30 and March 26, 1946. Decided April 22, 1946. A shipper who rented tank cars for transporting its products in interstate commerce brought suit in the District Court against the car company for the amount by which allowances received by the car company from carriers for use of the cars exceeded the rental. This Court, in General American Tank Car Corp. v. El Dorado Terminal Co., 308 U. S. 422, ordered the District Court to stay its hand until the Interstate Commerce Commission could determine the administrative problems involved. In response to a petition of the shipper, the Commission found that an allowance to the shipper in excess of the rental would be unjust, unreasonable and unlawful, and ordered the proceeding before it discontinued. Held: 1. The action of the Commission was a reviewable "order," and a suit to enjoin or set it aside was within the jurisdiction of a District Court of three judges. 28 U. S. C. §§ 41 (28), 47. P. 18. 2. The Commission's determination as to what constituted a just and reasonable allowance to the shipper was valid although it related to past transactions. P. 19. 12 Counsel for Parties. (a) The Commission made its determination, as to the lawfulness of the past practices, upon the application of the shipper. P. 19. (b) The determination of the Commission was authorized by the decision of this Court in the Tank Car case, as well as by the Interstate Commerce Act. P. 19. (c) The Commission was not required in this proceeding to establish uniform rates for the future for all shippers. P. 20. 3. The finding of the Commission that the allowances to this shipper were unjust and unreasonable was based on uniform treatment of all shipper-lessees, whom the Commission was justified in treating as a class apart. P. 20. 4. It is the duty of the Commission to abolish all practices which result in rebates or preferences. P. 21. 5. The fact that the freight was paid by the consignees at the regular rate does not preclude the finding that the practices here in question involved rebates or preferences to the shipper which are prohibited by the Interstate Commerce Act and the Elkins Act. P. 22. 59 F. Supp. 738, affirmed. Appellants' suit to set aside an order of the Interstate Commerce Commission, 258 I. C. C. 371, was dismissed by a District Court of three judges for want of jurisdiction, 59 F. Supp. 738, and appellants appealed to this Court. Affirmed on other grounds, p. 22. W. F. Williamson argued the cause and filed briefs for appellants. H. Russell Bishop entered an appearance for the El Dorado Oil Works, appellant. Daniel W. Knowlton argued the cause for the United States and the Interstate Commerce Commission, appellees. With him on the brief were Solicitor General McGrath and Walter J. Cummings, Jr. Mr. Knowlton also filed a brief for the Interstate Commerce Commission. Allan P. Matthew argued the cause for the General American Transportation Corporation, appellee. With him on the briefs were Kenneth F. Burgess and Douglas F. J. Carter Fort and Thomas L. Preston filed a brief for the Alabama Great Southern Railroad Company et al., appellees. MR. JUSTICE BLACK delivered the opinion of the Court. Appellants filed a complaint in the District Court under 28 U. S. C. 41 (28), challenging action taken by the Interstate Commerce Commission allegedly pursuant to instructions contained in an earlier opinion rendered by this Court in connection with these proceedings. 308 U. S. 422. The District Court dismissed the complaint for want of jurisdiction on the ground that the Commission's action did not amount to a reviewable "order" within the meaning of 28 U. S. C. 41 (28). The case is before us on direct appeal. 28 U. S. C. 345. The following facts constitute the background of this proceeding: El Dorado Oil Works, one of the appellants, processes, sells, and ships coconut oil in interstate commerce. Special kinds of tank cars are necessary for that distribution. The appellee, General American Tank Car Corporation,1 owns tank cars which it rents and leases to various shippers. In 1933, Oil Works made a contract with the Car Company to rent, for a period of three years, fifty tank cars at $27.50 per car per month, and such additional cars as it might need at $30 per car per month. The outstanding railroad tariffs, prescribing payment by the railroad of 112¢ per mile for the use of tank cars, contained rules which provided that the mileage would be paid only to the "party" whose "reporting marks" appeared on the cars. During part of the rental period here in question the rules provided that "mileage for the use of cars of private ownership will be paid . . . only to the car owner-not to a 1 General American Transportation Corporation has become the successor of the General American Tank Car Corporation. 12 Opinion of the Court. lessee." Since under the agreement the cars were to bear the "reporting marks" of the Car Company and not the Oil Works, and since Oil Works was a lessee, no tariffs authorized railroad mileage payments to Oil Works. Nevertheless, under the agreement Oil Works was to receive the full mileage allowance prescribed by the tariffs. The rent Oil Works was to pay to Car Company was to be taken out by Car Company from the mileage allowances it received from the railroads and the balance was to be paid by it to Oil Works. The railroad payments proved to be greatly in excess of the rental obligations, and Car Company regularly paid the difference to Oil Works, until July 1, 1934. July 2, 1934, the Interstate Commerce Commission, after an exhaustive investigation, handed down its findings, opinion, and conclusion in Use of Privately Owned Refrigerator Cars, 201 I. C. C. 323. It there drew a distinction between car owners as a class and car renters as a class. It found that car owners must have sufficient rental allowances, whether they rented to railroads or to shippers, to pay a reasonable return on investment, taking into consideration cost of maintenance, idle cars, etc. On the other hand the Commission found that car renters had no such fixed costs. The Commission's conclusion was that costs of rented cars to a shipper, including rent and incidentals, was the only allowance the shipper-lessee should receive from a railroad, directly or indirectly, and that if he receives more, the cost of transportation to him would be less than the cost of transportation to shippers generally, especially those who use cars furnished by the carriers. To make the railroad pay more for use of a car rented by a shipper than the rent he had to pay, was, according to the Commission, a violation of § 15 (13) of the Interstate Commerce Act, 49 U. S. C. 15 (13), in that it required the railroad to pay more for the car than was |