US SUPREME COURT DECISIONS

1. A cash prize received by the winner of a contest in musical composition is "gross income" within the meaning of § 22(a) of the Internal Revenue Code, and it is not a "gift" excluded from gross income by § 22(b)(3). Pp. 343 U. S. 713-714.

2. In computing under § 107(b) the tax on such a cash prize for a musical composition, the income should be attributed to the 36 months ending with the close of the year in which it was received -- not some earlier period of 36 months during which the taxpayer worked on the composition. Pp. 343 U. S. 714-716.

190 F.2d 680 affirmed.

The District Court held that a cash prize received by the winner of a contest in musical composition was a gift exempted from taxation by § 22(b)(3) of the Internal Revenue Code. 93 F.Supp. 660. The Court of Appeals reversed. 190 F.2d 680. This Court granted certiorari. 342 U.S. 896. Affirmed, p. 343 U. S. 716.