Ellis Campbell, Jr., Director of Internal Revenue for the Second Collection District of Texas v. Great National Life Insurance Company

With much deference to the clear, concise, and forceful opinion of the majority, and to the able opinion of the district court reported in 119 F.Supp. 57, et seq., I am constrained to dissent.

As an academic exercise in semantics, it seems to me that either the affirmative or the negative can be proved that is, that the word “rents” includes royalties, or that it does not include royalties. It has often been used in both senses as is demonstrated by a reference to the many cases collected under the subheading “royalty” to the word “rent” in 36 Words and Phrases, pp. 912-914, and the pocket…