Commissioner v. Glenshaw Glass Co.
E296201
Commissioner v. Glenshaw Glass Co. is a landmark 1955 U.S. Supreme Court case that broadly defined "gross income" under the Internal Revenue Code to include punitive damages and other undeniable accessions to wealth.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Commissioner v. Glenshaw Glass Co. canonical | 1 |
Statements (46)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
landmark case ⓘ tax law case ⓘ |
| appealFrom | United States Court of Appeals for the Third Circuit ⓘ |
| appliesTo |
punitive damages
ⓘ
treble damages ⓘ windfall recoveries ⓘ |
| category |
1955 in United States case law
ⓘ
United States Supreme Court cases ⓘ
surface form:
United States Supreme Court cases in tax law
|
| citationParallel |
75 S. Ct. 473
ⓘ
99 L. Ed. 483 ⓘ |
| clarifiedThat | Congress intended to exert the full measure of its taxing power in defining gross income. ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| decisionType | decision on appeal from the United States Court of Appeals ⓘ |
| definedTerm | gross income ⓘ |
| establishedTest | undeniable accession to wealth test for gross income ⓘ |
| hasCitation | 348 U.S. 426 ⓘ |
| hasCourt | Supreme Court of the United States ⓘ |
| hasDocketNumber |
No. 72
ⓘ
No. 73 ⓘ |
| holding |
Punitive damages are taxable as gross income.
ⓘ
Undeniable accessions to wealth, clearly realized, over which the taxpayer has complete dominion constitute gross income. ⓘ |
| interpretsSection | § 22(a) ⓘ |
| interpretsStatute | Internal Revenue Code of 1939 ⓘ |
| issue | Whether punitive damages received in a lawsuit are includible in gross income under the Internal Revenue Code. ⓘ |
| jurisdiction | federal ⓘ |
| justiceNotParticipating |
John M. Harlan II
ⓘ
surface form:
John Marshall Harlan II
|
| legalArea |
United States tax law
ⓘ
federal income tax law ⓘ |
| majorityOpinionBy | Earl Warren ⓘ |
| majorityOpinionVote | 8–0 ⓘ |
| overruledPrecedentInPart | Commissioner v. Wilcox ⓘ |
| pageInUnitedStatesReports | 426 ⓘ |
| petitioner | Commissioner of Internal Revenue ⓘ |
| relatedConcept |
accession to wealth
ⓘ
complete dominion over income ⓘ realization of income ⓘ |
| respondent |
Glenshaw Glass Company
ⓘ
William Goldman Theatres, Inc. ⓘ |
| result | Judgment of the Court of Appeals reversed. ⓘ |
| subsequentInfluence | Frequently cited in U.S. tax law for the definition of gross income. ⓘ |
| volumeOfUnitedStatesReports | 348 ⓘ |
| wasArguedOn | 1954-11-09 ⓘ |
| wasDecidedOn | 1955-03-28 ⓘ |
| wasRearguedOn | 1955-01-11 ⓘ |
| yearDecided | 1955 ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.