Greisen ex rel. Greisen v. United States

GOODWIN, Circuit Judge:

These three separate claims, consolidated in the district court, challenge the assessment of federal income tax on payments from Alaska’s Permanent Fund Dividend Program. Plaintiffs seek refund of taxes paid, claiming that Alaska’s distribution of its energy wealth to the state’s residents through the program is a “gift,” exempt from federal taxation. On cross-motions for summary judgment, the district court granted the government’s motion, finding that the payments were not gifts, and that they were “income” within the meaning of the sixteenth amendment and the…