The main purpose of the Longyear Foundation was to preserve "the records of the earthly life of Mary Baker Eddy," the founder of the Christian Science religion.

When the will was offered for probate in Massachusetts, there was objection by the heirs upon the grounds, among others, of lack of testamentary capacity and undue influence.

In that situation, a compromise agreement was entered into between the heirs, the legatees, the devisees, and the executors under the will and the Attorney General of Massachusetts.

The question presented was whether property received from the estate of a decedent in compromise of a claim (settlement of litigation) as an heir was taxable as income.

Because of a conflict with the decision of the Court of Appeals for the Fourth Circuit in Magruder v. Segebade,[2] certiorari was granted.