Louis Brandeis

“ To hold, as the prevailing opinion seems to do, that every payment which in any aspect is a gift is perforce not compensation and hence relieved of any tax, is to work havoc with the law. A large body of decisions, whose provenance is Old Colony Trust Co. ”

“ Perhaps, if such a function had been ours, we would have drawn the inference favoring a gift. That is not enough. If there was opportunity for opposing inferences, the judgment of the Board controls. Elmhurst Cemetery Co. ”