TAXATION: Multiplication and Deduction

When Lloyd Wilson of San Francisco, publicity man for the Y.M.C.A., made out his income tax for 1936, he wondered how much to deduct for his baby daughter, Helen. Had she been born in January of that year he would have deducted the full $400 allowance for a dependent. But she had been born in August. That certainly entitled him to deduct five-twelfths of $400.

Then it occurred to Taxpayer Wilson that his new dependent had been living, at least since her moment of "quickening" as a three-month-old embryo, in February 1936. Father Wilson allowed himself a deduction of eleven-twelfths of $400. The Bureau of Internal Revenue came back at him for $6.18 tax deficiency on that return, allowing him exemption for Baby Helen only after her birth.

Last week Lloyd Wilson came back at the Bureau. Not to save $6.18 (filing an appeal cost him $10) but to establish a point that "could mean a big saving for a lot of people," he argued that the law recognizes unborn children as living human beings in many other instances. It permits a child to inherit from a father who dies before the child is born. It calls abortion murder. Mrs. Wilson also added an argument: "The doctor's bill started long be fore the child was born. . . . The cost of supporting a child doesn't wait until its birth." The board of Tax Appeals, lacking a precedent to go by, reserved decision.