Healy v. Commissioner

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that when a taxpayer restores an item of income in a later tax year, changes in income or fluctuations in tax rates between the year of receipt and the year of repayment could disadvantage the taxpayer
• noting that when a taxpayer restores an item of income in a later tax year, changes in income or fluctuations in tax rates between the year of receipt and the year of repayment could disadvantage the taxpayer
• distinguishing funds received “un- der a claim of right as a trustee” and those received “under a claim of individual right”
• \A constructive trust is a fiction imposed as an equitable device for achieving justice.\ (emphasis added) (citation omitted)
• \[a] constructive trust is a fiction imposed as an equitable device for achieving justice\
• “[a] constructive trust is a fiction imposed as an equitable device for achieving justice”

Source: CourtListener parenthetical corpus (CC0).