Eisner v. Macomber

E296200

Eisner v. Macomber is a 1920 U.S. Supreme Court case that held a pro rata stock dividend was not taxable income under the Sixteenth Amendment, shaping early federal income tax doctrine.

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Eisner v. Macomber canonical 1

Statements (44)

Predicate Object
instanceOf United States Supreme Court case
constitutional law case
tax law case
appliesTo pro rata stock dividends
concernsAmendment Sixteenth Amendment to the United States Constitution
concernsAreaOfLaw constitutional limitations on taxation
federal income tax
establishedDoctrine narrow definition of income for Sixteenth Amendment purposes
realization requirement for income taxation
hasCitation 252 U.S. 189
hasCountry United States of America
hasCourt Supreme Court of the United States
hasDecisionDate 1920-03-08
hasDissentBy Justice James C. McReynolds
Justice John H. Clarke
Justice Louis D. Brandeis
Oliver Wendell Holmes Jr.
surface form: Justice Oliver Wendell Holmes Jr.
hasHistoricalContext post-ratification interpretation of the Sixteenth Amendment
hasImpactOn Internal Revenue Code interpretation
constitutional constraints on federal tax policy
hasJurisdiction federal
hasKeyConcept income
realization
stock dividend
hasLanguage English
hasLegalSignificance limited congressional power to tax certain unrealized gains as income
shaped early federal income tax doctrine
hasMajorityOpinionBy Justice Mahlon Pitney
hasPage 189
hasPetitioner Eisner
hasReporter United States Reports
hasRespondent Macomber
hasSubsequentTreatment narrowed by later Supreme Court income tax decisions
hasVolume 252
hasVote 5–4
hasYear 1920
holding A pro rata stock dividend is not taxable income under the Sixteenth Amendment
Stock dividends representing a capitalization of surplus are not realized income to shareholders
interprets Sixteenth Amendment to the United States Constitution
surface form: Sixteenth Amendment power to tax incomes without apportionment
involvesIssue definition of income under the Sixteenth Amendment
realization of gain
taxability of stock dividends
isTaughtIn United States constitutional law courses
United States federal income tax law courses

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