Commissioner of Internal Revenue v. Glenshaw Glass Company

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Commissioner of Internal Revenue v. Glenshaw Glass Company (1955)
the Supreme Court of the United States

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Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955), was an important income tax case before the United States Supreme Court. The Court held as follows:

Congress, in enacting income taxation statutes that comprehend "gains or profits and income derived from any source whatever," intended to tax all gain except that which was specifically exempted.

Income is not limited to "the gain derived from capital, from labor, or from both combined."

Although the Court used this characterization in Eisner v. Macomber, it "was not meant to provide a touchstone to all future gross income questions."

Instead, income is realized whenever there are "instances of [1] undeniable accessions to wealth, [2] clearly realized, and [3] over which the taxpayers have complete dominion."

Under this definition, punitive damages qualify as "income" — even though they are not derived from capital or from labor.

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United States Supreme Court

348 U.S. 426

Commissioner of Internal Revenue v. Glenshaw Glass Company

Argued: Feb. 28, 1955. --- Decided: March 28, 1955

See 349 U.S. 925, 75 S.Ct. 657.

Solicitor General, Simon E. Sobeloff, Washington, D.C., for petitioner.

Mr.Max Swiren, Chicago, Ill., for respondent Glenshaw Glass Co.

Mr. Samuel H. Levy, Philadelphia, Pa., for respondent Wm. Goldman Theatres, Inc.

Mr. Chief Justice WARREN delivered the opinion of the Court.

Notes

This work is in the public domain in the United States because it is a work of the United States federal government (see 17 U.S.C. 105).

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