UNITED STATES V. LEWIS, 340 U. S. 590 (1951)

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U.S. Supreme Court

United States v. Lewis, 340 U.S. 590 (1951)

United States v. Lewis

No. 347

Argued March 2, 1951

Decided March 26, 1951

340 U.S. 590


In his 1944 income tax return, respondent reported $22,000 received that year as an employee's bonus, which he claimed in good faith and used unconditionally as his own. In subsequent litigation, it was decided that the bonus had been computed improperly, and, under compulsion of a judgment, respondent returned $11,000 to his employer in 1946. He then sued in the Court of Claims for refund of an alleged overpayment of his 1944 income tax.

Held: under the "claim of right" doctrine announced in North American Oil v. Burnet, 286 U. S. 417, the entire $22,000 was income in 1944, and respondent was not entitled to recompute his 1944 tax. Pp. 340 U. S. 590-592.

117 Ct.Cl. 336, 91 F.Supp. 1017, reversed.

The case is stated in the opinion. The judgment below is reversed, p. 340 U. S. 592.