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.
All labels observed (1)
| Label | Occurrences |
|---|---|
| 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 ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.