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ROCKEFELLER v. C. I. R.

Nos. 886, 889, Dockets 81-4197, 81-4199.

676 F.2d 35 (1982)

David ROCKEFELLER and Margaret McG. Rockefeller, Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellant. ESTATE OF John D. ROCKEFELLER, 3rd, Deceased, John D. Rockefeller, IV, J. Richardson Dilworth and Donal C. O'Brien, Jr., Executors, and Blanchette H. Rockefeller, Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Second Circuit.

Decided April 9, 1982.

Attorney(s) appearing for the Case

Richard Farber, Dept. of Justice, Tax Div., Washington, D. C. (Glenn L. Archer, Asst. Atty. Gen. of the U. S., Michael L. Paup, Anthony Ilardi, Jr., Dept. of Justice, Tax Div., Washington, D. C., of counsel), for appellant.

William E. Jackson, New York City (Howard A. Bolton, Stuart E. Keebler and Joseph M. Persinger, Milbank, Tweed, Hadley & McCloy, New York City, of counsel), for appellees.

Before KAUFMAN, MANSFIELD and CARDAMONE, Circuit Judges.

IRVING R. KAUFMAN, Circuit Judge:

In divining the meaning of statutory words, courts have long followed the principle that the legislature is the master,1 and that statutory interpretation therefore involves a search for evidence of legislative intent.2 As Justice Frankfurter aptly phrased it, "[t]he Court's task is to construe not English but congressional English."3 Since words...

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