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Commissioner v. Bilder

369 U.S. 499, 82 S. Ct. 881, 8 L. Ed. 2d 65 (1962)

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Commissioner v. Bilder

United States Supreme Court

369 U.S. 499, 82 S. Ct. 881, 8 L. Ed. 2d 65 (1962)

Facts

Robert Bilder (plaintiff) was an attorney who suffered a series of heart attacks over the course of eight years. Due to Bilder’s heart condition, his doctor recommended that he spend the winter months in a warm climate. In 1954 Bilder, accompanied by his wife and daughter, rented an apartment in Florida for three months. In 1955 Bilder and his family rented a different apartment in Florida for two months. On his income-tax returns for 1954 and 1955, Bilder included his rental payments as deductible medical-care expenses under § 213 of the Internal Revenue Code. The Commissioner of Internal Revenue (the Commissioner) (defendant) disallowed the deductions. The United States Tax Court reversed the Commissioner and allowed Bilder to take a deduction for one-third of the cost of his rent. The tax court reasoned that two-thirds of the rent went toward Bilder’s wife and daughter and therefore was not related to Bilder’s medical treatment. The court of appeals reversed the tax court and held that Bilder could deduct the entire cost of his rent for the two winters. The Commissioner appealed.

Rule of Law

Issue

Holding and Reasoning (Harlan, J.)

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