John Marshall Harlan II

“ For example, if a doctor prescribes that a patient must go to Florida in order to alleviate specific chronic ailments and to escape unfavorable climatic conditions which have proven injurious to the health of the taxpayer, and the travel is prescribed for reasons other than the general improvement of a patient's health, the cost of the patient's transportation to Florida would be deductible but not his living expenses while there. However, if a doctor prescribed an appendectomy and the taxpayer chose to go to Florida for the operation not even his transportation costs would be deductible. ”

“ On cross-appeals from the decision of the Tax Court, the Court of Appeals held, by a divided vote, that the full rental payments were deductible as expenses for 'medical care' within the meaning of § 213. ”

“ M17 (1954) ; Memorandum of Joint Committee on Internal Revenue Taxation, 1 Senate Hearings on the Internal Revenue Code of 1954, 83d Cong., 2d Sess. 24 (1954) ; Memorandum of the Under Secretary of the Treasury, id., at 103. It is that factor which is of controlling importance here. [5]
We need not consider whether we would be warranted in disregarding these unequivocal expressions of legislative intent if the statute were so written as to permit no reasonable construction other than that urged on behalf of the taxpayer. ”