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HELVERING V. BLISS, 293 U. S. 144 (1934)

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U.S. Supreme Court

Helvering v. Bliss, 293 U.S. 144 (1934)

Helvering v. Bliss

No. 6

Argued October 9, 10, 1934

Decided November 5, 1934*

293 U.S. 144


1. The base for computing the 15 percent deduction allowable for charitable contributions under § 23(n) of the Revenue Act of 1928 is the "net income" defined by § 21, and includes capital net gain, even though the taxpayer elect to be taxed on capital net gain at the reduced rate prescribed by § 101(a). P. 293 U. S. 150.

2. This construction of the Act is required by its language and legislative history. P. 293 U. S. 147.

3. The right of the taxpayer in computing net income to make deductions for charitable contributions, as expressly provided by § 23(n) of the Act, is not modified by § 101, which merely prescribes a method for taxing a portion of the net income (capital net gain) at a special rate. P. 293 U. S. 150.

4. The allowance of deductions on account of charitable contributions and the reduction of the rate of tax on capital gains were liberalizations of the law in the taxpayer's favor, based upon considerations of public policy, and are not to be narrowly construed. Pp. 293 U. S. 150-151. chanroblesvirtualawlibrary

Page 293 U. S. 145

5. The reduction in the rate of tax upon capital gains should not be held to circumscribe the privilege granted in earlier acts, and retained in later ones, with respect to charitable contributions, unless that result be plainly required by the language used. P. 293 U. S. 151.

6. The reenactment in Acts subsequent to the 1921 Act of the sections permitting the deduction for charitable contributions indicates congressional approval of the uniform administrative interpretation through the years from 1923 to 1932. P. 293 U. S. 151.

68 F.2d 890; id., 1004, affirmed.

Certiorari, 292 U.S. 617, to review judgments reversing decisions of the Board of Tax Appeals, 27 B.T.A. 205, which sustained the Commissioner and redetermined deficiencies in income taxes.

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