| Commissioner v. Glenshaw Glass Co. | |
|---|---|
 | |
| Argued February 28, 1955 Decided March 28, 1955 | |
| Full case name | Commissioner of Internal Revenue v. Glenshaw Glass Company |
| Citations | 348 U.S. 426 (more) 75 S. Ct. 473; 99 L. 483; 1955 U.S. LEXIS 1508; 55-1 U.S. Tax Cas. (CCH) ¶ 9308; 47 A.F.T.R. (P-H) 162; 1955-1 C.B. 207 |
| Case history | |
| Prior | Glenshaw Glass Co. v. Comm'r, 18 T.C. 860 (1952); William Goldman Theatres, Inc. v. Comm'r, 19 T.C. 637 (1953); affirmed, Comm'r v. Glenshaw Glass Co., 211 F.2d 928 (3d Cir. 1954); cert. granted, 348 U.S. 813 (1954). |
| Subsequent | Rehearing denied, 349 U.S. 925 (1955). |
| Holding | |
| The Court held that Congress, in enacting the income taxation statutes, intended to tax all gain except that which was specifically exempted. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Warren, joined by Black, Reed, Frankfurter, Burton, Clark, Minton |
| Dissent | Douglas |
| Harlan took no part in the consideration or decision of the case. | |
| Laws applied | |
| Internal Revenue Code | |
Wikisource has original text related to this article:
Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955), was an important income tax case before the United States Supreme Court. The Court held as follows:
- Congress, in enacting income taxation statutes that comprehend "gains or profits and income derived from any source whatever," intended to tax all gain except that which was specifically exempted.
- Income is not limited to "the gain derived from capital, from labor, or from both combined."
- Although the Court used this characterization in Eisner v. Macomber, it "was not meant to provide a touchstone to all future gross income questions."
- Instead, income is realized whenever there are "instances of [1] undeniable accessions to wealth, [2] clearly realized, and [3] over which the taxpayers have complete dominion."
- Under this definition, punitive damages qualify as "income" -- even though they are not derived from capital or from labor.[1]
- ^ Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 430-31 (1955).