Commissioner of Internal Revenue v. Shamberg's Estate

1. To ascertain what the legislature meant is often a difficult judicial task, difficult usually not because (as legislaturebaiters put it) the legislature carelessly chose its words but because it could not anticipate all the circumstances to which ingenious future litigants would seek to apply those words.1 Our task involves a greater difficulty: We must try to ascertain, guided by precedents not always close to the case in hand, whát the Supreme Court, when the statute comes before it, will think Congress intended. In a case like this, almost certain to be reviewed, it may seem that any…