Helvering v. Reynolds

Me. Justice Roberts:

I disagreed with the decisions of the Court in Maguire v. Commissioner, ante, p. 1, Helvering v. Gambrill, ante, p. 11, and Helvering v. Campbell, ante, p. 15, construing the meaning of the phrase “time of distribution to the taxpayer,” as used in § 113a (5) of the Revenue Acts of .1928 and 1932. My dissent was bottomed upon the view that to construe that phrase as meaning the time of the distribution to a trustee, in a case where the taxpayer could neither receive nor enjoy the property, was to disregard the unambiguous words of the statute. I recognize the binding force…