Stein v. Commissioner
United States Tax Court
1. In observance of the one-hundredth anniversary of the founding of its business a business corporation, late in 1943, by paid advertisement, offered 17 awards totaling $ 50,000 to the persons submitting the best and most constructive 17 plans for postwar employment in the United States. The plan submitted by the petitioner was adjudged the best of more than 35,000 entries and in May, 1944, he received $ 25,000 as payment of the first award.
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1. In observance of the one-hundredth anniversary of the founding of its business a business corporation, late in 1943, by paid advertisement, offered 17 awards totaling $ 50,000 to the persons submitting the best and most constructive 17 plans for postwar employment in the United States. The plan submitted by the petitioner was adjudged the best of more than 35,000 entries and in May, 1944, he received $ 25,000 as payment of the first award. All manuscripts and plans became the property of the corporation, with the right to publish and distribute them. After announcement of the awards the…
1Opinion of the Court
OPINION.
Turner, Judge:
The question here is whether the $25,000 in war bonds awarded to petitioner by Pabst was taxable income within the meaning of the Internal Revenue Code. By the Sixteenth Amendment to the Constitution, Congress was given the power to lay and collect taxes on incomes “from whatever source derived.” Thereafter the Supreme Court, in considering the scope of the power of Congress to tax as expanded by the Sixteenth Amendment, said that “income may be defined as the gain derived from capital, from labor, or from both combined.” Eisner v. Macomber, 252 U. S. 189. Congress, in…
2Cases cited4 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- German v. CommissionerUnited States Tax Court · 1943
3Cited by18 opinions
- Banks v. CommissionerUnited States Tax Court · 1952
- Stone v. CommissionerUnited States Tax Court · 1954
- Teschner v. CommissionerUnited States Tax Court · 1962
- United States v. RobertsonCourt of Appeals for the Tenth Circuit · 1951
- Ti Li Loo v. CommissionerUnited States Tax Court · 1954
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