Legal Opinion

Goodrich v. Edwards

Supreme Court of the United States

Decided April 11, 1921No. 663PublishedCited by 114 opinions

ERROR TO THE DISTRICT COURT OP THE UNITED STATES POR THE SOUTHERN DISTRICT OP NEW YORK. The case is stated in the opinion. The increase in value of property held for investment, when realized by sale, is not “income” within the meaning of the Sixteenth Amendment. Income here is to be taken as having the meaning commonly understood and judicially defined.

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ERROR TO THE DISTRICT COURT OP THE UNITED STATES POR THE SOUTHERN DISTRICT OP NEW YORK. The case is stated in the opinion. The increase in value of property held for investment, when realized by sale, is not “income” within the meaning of the Sixteenth Amendment. Income here is to be taken as having the meaning commonly understood and judicially defined. Eisner v. Macomber, 252 U. S. 189; McCulloch v. Maryland, 4 Wheat. 316, 407. Prior to the Amendment, income had been judicially defined by this court in Gray v. Darlington, 15 Wall. 63, by the highest courts of many of the States in the law…

1Opinion of the CourtJustice Clarke

The plaintiff in error sued the defendant, a collector of Internal Revenue, to recover income taxes assessed in 1920 for the year 1916 and paid under protest to avoid penalties. A demurrer to the complaint was sustained and the constitutional validity of a law of the United States is so involved, that the case is properly here by writ of error. Towne v. Eisner, 245. U. S. 418.

Two transactions are involved.(1) In 1912 the plaintiff in error purchased 1,000 shares of the capital stock of a mining company for which he paid $500. It is averred that the stock was worth $695 on March 1, .1913,- and…

2Cases cited1 opinion

  1. Eisner v. MacOmberSupreme Court of the United States · 1920

3Cited by114 opinions

  1. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  2. Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
  3. Willcutts v. BunnSupreme Court of the United States · 1931
  4. Hellmich v. HellmanSupreme Court of the United States · 1928
  5. United States v. FlannerySupreme Court of the United States · 1925

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