Simon v. Commissioner
Dissent
### Dissent

The [dissent](/wiki/Dissenting_opinion "Dissenting opinion") asserted that the majority decision gives an improper "[tax shelter](/wiki/Tax_shelter "Tax shelter")" for musicians. They state that the [Internal Revenue Code](/wiki/Internal_Revenue_Code "Internal Revenue Code"), in accordance with congressional intent, meant for these "works of art" to be non\-depreciable property since instruments and other collectibles have an indeterminable useful life.


Is there a particular reason why Congress wanted these works to be treated differently from other property?