In case I didn't write clearly enough above: 1) When J. Learned Hand wrote the opinion containing the quote above, he was not yet a U.S. Supreme Court justice, he was serving on the 2nd Circuit Court of Appeals; 2) the complete lowdown on the entire saga of the Helvering v. Gregory tax case is found in a scholarly thesis located at this website: http://law.bepress.com/cgi/viewcontent.cgi?article=1070&context=taulwps&sei-redir=1#search=%22learned+hand+tax+decisions%22