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HIGGINS v. COMMISSIONER

No. 253.

312 U.S. 212 (1941)

HIGGINS v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided February 3, 1941.

Attorney(s) appearing for the Case

Mr. Selden Bacon, with whom Mr. Orwill V.W. Hawkins was on the brief, for petitioner.

Mr. Arnold Raum, with whom Solicitor General Biddle, Assistant Attorney General Clark, and Messrs. Sewall Key and Lee A. Jackson were on the brief, for respondent.

Messrs. Rollin Browne, John G. Jackson, Jr., and George Craven filed a brief, as amici curiae, urging reversal.

MR. JUSTICE REED delivered the opinion of the Court.

Petitioner, the taxpayer, with extensive investments in real estate, bonds and stocks, devoted a considerable portion of his time to the oversight of his interests and hired others to assist him in offices rented for that purpose. For the tax years in question, 1932 and 1933, he claimed the salaries and expenses incident to looking after his properties were deductible under § 23 (a) of

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