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HEALY v. COMMISSIONER.

No. 76.

345 U.S. 278 (1953)

HEALY ET AL. v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided April 6, 1953.

Attorney(s) appearing for the Case

James H. Heffern argued the cause and filed a brief for petitioners in No. 76.

Assistant Attorney General Lyon argued the cause for petitioner in No. 138 and respondent in No. 76. With him on the briefs were Ellis N. Slack, Lee A. Jackson and Melva M. Graney. Solicitor General Cummings was also on the brief in No. 76. Robert L. Stern, then Acting Solicitor General, and Philip Elman were also on the brief in No. 138.

Sol Goodman argued the cause and filed a brief for respondent in No. 138.

MR. CHIEF JUSTICE VINSON delivered the opinion of the Court.

The income tax liability of three individual taxpayers for a given year is here before the Court. Only a single question, common to all the cases, is involved. The Tax Court held a view favorable to the taxpayers.1 The Commissioner of Internal Revenue sought review before the appropriate Courts of Appeals. As to two of the taxpayers, the Court of Appeals for the Second Circuit...

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