Sounds logical enough to me. Of course legal logic isn't always desirable in taxation statutes... which is part of the reason why any sane constitutional judge would stay as clear of them as he possibly can (which isn't always very much).
I'm assuming that you were referring to the 1962 case that has a wiki article. There are several cases by that name.
Not a SC decision, but I'll throw it out anyways just because I've just read it (after reading the book and randomly googling Ruby's name)
Haynes vs Knopf Inc. and Lemann
