William Goldman Theatres v. Commissioner
United States Tax Court
Income -- Punitive Damages. -- Petitioner, as an injured party, received a damage judgment in an antitrust suit. Held, one-third of the award was compensatory damages for loss of profits and taxable as income. Held, further, that two-thirds of the award was punitive damages and not taxable.
1Opinion of the Court
OPINION.
Johnson, Judge:
Petitioner has reported as taxable income $125,000 of a total $375,000 judgment received upon the successful prosecution of an antitrust suit. The award was made under what is commonly known as section 4 of the Clayton Act (15 U. S. C. A. 15).1
Respondent maintains that the excess ($250,000) by which the award exceeds the actual damages ($125,000) constitutes taxable income under section 22 (a) of the Internal Revenue Code and the Sixteenth Amendment. Respondent also contends that the entire award in this case was for loss of profits and therefore the entire amount is…
2Cases cited15 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Bigelow v. RKO Radio Pictures, Inc.Supreme Court of the United States · 1946
- Chattanooga Foundry & Pipe Works v. City of AtlantaSupreme Court of the United States · 1906
- Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
- City of Atlanta v. Chattanooga Foundry & PipeworksCourt of Appeals for the Sixth Circuit · 1903
10 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Freeman v. CommissionerUnited States Tax Court · 1959
- Commissioner of Internal Revenue v. Glenshaw Glass Co. Commissioner of Internal Revenue v. William Goldman Theatres, IncCourt of Appeals for the Third Circuit · 1954
- Commissioner of Internal Revenue v. Obear-Nester Glass CompanyCourt of Appeals for the Seventh Circuit · 1954
- General American Investors Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
7 more not listed; retrieve them via the Exa API.