Union Assurance Society, Ltd. v. United States

I am unable to concur in the majority opinion. The Commissioner of Internal Revenue has authority to make rules and regulations within the general scope of the Act which are addressed to and reasonably adapted to its enforcement, but he may not extend a statute or modify its meaning. Campbell v. Galeno Chemical Co., 281 U. S. 599, 610; International Railway Co. v. Davidson, 257 U. S. 506, 514; United States v. 200 Barrels of Whiskey, 95 U. S. 571; Maryland Casualty Co. v. United States, 251 U. S. 342; St. Louis Refrigerating & Cold Storage Co. v. United States, 95 C. Cls. 707. The regulation…