Brushaber v. Union Pacific Railroad Co.

E349807

Brushaber v. Union Pacific Railroad Co. is a 1916 U.S. Supreme Court case that upheld the federal income tax and clarified the scope and constitutionality of the Sixteenth Amendment.

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Predicate Object
instanceOf United States Supreme Court case
federal income tax case
areaOfLaw federal constitutional tax law
citation 240 U.S. 1
36 S. Ct. 236
60 L. Ed. 493
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1916-01-24
defendant Union Pacific Railroad
surface form: Union Pacific Railroad Company
dissentingJustices none
distinguishedFrom Pollock v. Farmers' Loan & Trust Co.
surface form: Pollock v. Farmers’ Loan & Trust Co.
fullName Brushaber v. Union Pacific Railroad Co. self-linksurface differs
surface form: Frank R. Brushaber v. Union Pacific Railroad Company
holding The Supreme Court held that the Sixteenth Amendment authorizes a non-apportioned direct income tax.
Sixteenth Amendment to the United States Constitution
surface form: The Supreme Court held that the Sixteenth Amendment removed the requirement of apportionment for taxes on incomes from whatever source derived.

The Supreme Court held that the income tax under the Sixteenth Amendment is not required to be apportioned among the states according to population.
United States taxation and revenue case law
surface form: The Supreme Court rejected the argument that the income tax violated the Fifth Amendment Due Process Clause.

United States taxation and revenue case law
surface form: The Supreme Court rejected the argument that the income tax was a taking of property without due process of law.

Revenue Act of 1913
surface form: The Supreme Court upheld the constitutionality of the federal income tax imposed by the Revenue Act of 1913.
issue whether the Sixteenth Amendment changed the classification of income taxes as direct or indirect taxes
whether the federal income tax under the Revenue Act of 1913 violated constitutional requirements of apportionment
whether the income tax violated the Fifth Amendment Due Process Clause
jurisdiction federal
languageOfProceedings English
legalEffect clarified the scope of the Sixteenth Amendment
confirmed the federal government’s power to levy an income tax without apportionment among the states
limited challenges to the federal income tax based on direct tax and apportionment arguments
legalSubject Sixteenth Amendment to the United States Constitution
federal income tax
taxing and spending power of the United States
majorityOpinionBy Charles Evans Hughes
partyType individual taxpayer vs. corporation
plaintiff Frank R. Brushaber
precededBy Pollock v. Farmers' Loan & Trust Co.
surface form: Pollock v. Farmers’ Loan & Trust Co.
recognizedPrinciple Congress may tax incomes from property without apportionment under the Sixteenth Amendment
the Sixteenth Amendment did not confer a new power of taxation but removed the apportionment requirement for income taxes
relatedConstitutionalProvision Article I, Section 2 of the United States Constitution
Article I, Section 9 of the United States Constitution
Fifth Amendment to the United States Constitution
Sixteenth Amendment to the United States Constitution
relatedLegislation Revenue Act of 1913
result judgment for Union Pacific Railroad Company
subsequentCitation cited as precedent in later income tax and Sixteenth Amendment cases
topic United States constitutional law
tax law
vote 8–0
yearDecided 1916

Referenced by (3)

Full triples — surface form annotated when it differs from this entity's canonical label.

Sixteenth Amendment to the United States Constitution relatedCourtCase Brushaber v. Union Pacific Railroad Co.
Direct Tax Clause of the United States Constitution interpretedInCase Brushaber v. Union Pacific Railroad Co.
Brushaber v. Union Pacific Railroad Co. fullName Brushaber v. Union Pacific Railroad Co. self-linksurface differs
this entity surface form: Frank R. Brushaber v. Union Pacific Railroad Company