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Commissioner v. Heininger

United States Supreme Court
320 U.S. 467 (1943)

Written by Heather Whittemore, JD

Facts

S. B. Heininger (plaintiff) was a dentist who made false teeth and sold them by mail order. Heininger was accused of mail fraud stemming from allegations that his advertisements, distributed by mail, were false. The postmaster general issued a fraud order forbidding Heininger from receiving money orders and mail. Heininger, believing that he had not committed mail fraud, appealed the fraud order, and the district court found in his favor. The court of appeals reversed the district court and reinstated the order. Over the course of the litigation, Heininger incurred large legal expenses and claimed them as business expenses on his income-tax returns. The Commissioner of Internal Revenue (the Commissioner) (defendant) disallowed the deductions, arguing that they were not ordinary and necessary business expenses. The United States Tax Court affirmed the Commissioner, and the court of appeals reversed. The Commissioner appealed.

Rule of Law

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Issue

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Holding and Reasoning (Black, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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