Smith v. Shaughnessy

318 U.S. 176 (1943)

SMITH

v.

SHAUGHNESSY, COLLECTOR OF INTERNAL REVENUE.

No. 429.

Supreme Court of United States.

Argued January 14, 1943.

Decided February 15, 1943.

CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE SECOND CIRCUIT.

Mr. Ellsworth C. Alvord, with whom Messrs. Floyd F. Toomey, John H. Hughes, and Willis H. Michell were on the brief, for petitioner.

Mr. Arnold Raum, with whom Solicitor General Fahy, Assistant Attorney General Clark, and Messrs. Sewall Key, J. Louis Monarch, and L.W. Post were on the brief, for respondent.

The question here is the extent of the petitioner's liability for a…