Healy v. Commissioner

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. 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 re versed, 2 while the Court of Appeals for the Sixth Circuit took a contrary view of the law. 3 We granted certiorari to resolve the conflict. 4

All controlling facts in the three situations are similar. Each taxpayer…