US LAWS, STATUTES and CODES : Chan Robles Virtual Law Library USA Supreme Court Decisions | Resolutions : Chan Robles Virtual Law Library

ChanRobles™ Virtual Law Library™ |™   
Main Index Repository of Laws, Statutes and Codes Latest Philippine Supreme Court Decisions Chan Robles Virtual Law Library Latest Legal Updates Philippine Legal Resources Significant Philippine Legal Resources Worldwide Legal Resources Philippine Supreme Court Decisions United States Legal Resources United States Supreme Court Jurisprudence ChanRobles LawTube - Social Network

ChanRobles Internet Bar Review : DebtKollect Company, Inc. - Debt Collection Firm Intellectual Property Division - Chan Robles Law Firm

Philippine Supreme Court DecisionsChanRobles On-Line Bar Review

google search for chanrobles.comSearch for


Subscribe to Cases that cite 348 U. S. 426 RSS feed for this section

U.S. Supreme Court

Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955)

Commissioner v. Glenshaw Glass Co.

No. 199

Argued February 28, 1955

Decided March 28, 1955*

348 U.S. 426


Money received as exemplary damages for fraud or as the punitive two-thirds portion of a treble damage antitrust recovery must be reported by a taxpayer as "gross income" under § 22(a) of the Internal Revenue Code of 1939. Pp. 348 U. S. 427-433.

(a) In determining what constitutes "gross income" as defined in § 22(a), effect must be given to the catch-all language "gains or profits and income derived from any source whatever." Pp. 348 U. S. 429-430.

(b) Eisner v. Macomber, 252 U. S. 189, distinguished. Pp. 348 U. S. 430-431.

(c) The mere fact that such payments are extracted from the wrongdoers as punishment for unlawful conduct cannot detract from their character as taxable income to the recipients. P. 348 U. S. 431.

(d) A different result is not required by the fact that § 22 (a) was reenacted without change after the Board of Tax Appeals had held punitive damages nontaxable in Highland Farms Corp., 42 B.T.A. 1314. Pp. 348 U. S. 431-432.

(e) The legislative history of the Internal Revenue Code of 1954 does not require a different result. The definition of gross income was simplified, but no effect upon its present broad scope was intended. P. 348 U. S. 432.

(f) Punitive damages cannot be classified as gifts, nor do they come under any other exemption in the Code. P. 348 U. S. 432.

211 F.2d 928 reversed. chanroblesvirtualawlibrary

Page 348 U. S. 427

ChanRobles™ LawTube

google search for Search for

Supreme Court Decisions Philippine Supreme Court DecisionsUS Supreme Court Decisions



Browse By ->> Volume


Browse By ->> Year


  Copyright © ChanRobles Publishing Company | Disclaimer | E-mail Restrictions
ChanRobles™ Virtual Law Library |™