Flint v. Stone Tracy Co.

Flint v. Stone Tracy Co.
Supreme Court of the United States
Argued March 17–18, 1910 Reargued January 17–19, 1911 Decided March 13, 1911
Full case name	Stella P. Flint, as General Guardian of the Property of Samuel N. Stone, Junior, a Minor, Appt. v. Stone Tracy Company, et al.
Citations	220 U.S. 107 (more) 31 S. Ct. 342; 55 L. Ed. 389; 1911 U.S. LEXIS 1664
Holding
The privilege of operating in corporate form is valuable and justifies imposition of an income tax.
Court membership
Chief Justice Edward D. White Associate Justices John M. Harlan · Joseph McKenna Oliver W. Holmes Jr. · William R. Day Horace H. Lurton · Charles E. Hughes Willis Van Devanter · Joseph R. Lamar
Case opinions
Majority	Day, joined by White, McKenna, Holmes, Lurton, Hughes, Lamar.
Dissent	Harlan, joined by Van Devanter

Flint v. Stone Tracy Co., 220 U.S. 107 (1911), was a United States Supreme Court case in which a taxpayer challenged the validity of a federal income tax on corporations.^[1] The privilege of incorporation is a state function, and the challengers argued that only the states should tax corporations. The Court ruled that the privilege of operating in corporate form is valuable and justifies imposition of a federal income tax:

The continuity of the business, without interruption by death or dissolution, the transfer of property interests by the disposition of shares of stock, the advantages of business controlled and managed by corporate directors, the general absence of individual liability, these and other things inhere in the advantages of business thus conducted, which do not exist when the same business is conducted by private individuals or partnerships.