Druker v. State Tax Commission

Braucher, J.

(dissenting). I find G. L. c. 62, § 4, as appearing in St. 1971, c. 555, § 5, clear on its face, and the taxpayer’s interpretation seems to me to be a perverse misreading. Under § 4 (a) interest, dividends, and capital gains were taxed at 9 % if “included in the income subject to taxation.” The taxpayer received such income, and it was so included. Other income, taxable at 5% under § 4 (b), was also included in “income subject to taxation,” but the net balance of other income was negative. Most of the taxpayers of the Commonwealth understood the principle and paid their taxes accordingly, and I cannot join in a special windfall to an ingenious taxpayer who claims not to understand *203negative or minus numbers. I also disagree with the court’s disregard of trusts deliberately set up by the taxpayer to enable him to claim that there was or was not a trust, whichever might be to his advantage.