Commissioner v. Glenshaw Glass Co.
| Commissioner v. Glenshaw Glass Co. | |
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| Argued February 28, 1955 Decided March 28, 1955 |
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| Full case name | Commissioner of Internal Revenue v. Glenshaw Glass Company |
| Citations | 348 U.S. 426 (more)
75 S. Ct. 473; 99 L. Ed. 483; 1955 U.S. LEXIS 1508; 55-1 U.S. Tax Cas. (CCH) P9308; 47 A.F.T.R. (P-H) 162; 1955-1 C.B. 207
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| Prior history | Certiorari to the United States Court of Appeals for the Third Circuit |
| Holding | |
| The Court held that Congress, in enacting the income taxation statutes, intended to tax all gain except that which was specifically exempted. | |
| Court membership | |
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| Case opinions | |
| Majority | Warren, joined by Black, Reed, Frankfurter, Burton, Clark, Minton |
| Dissent | Douglas |
| Harlan took no part in the consideration or decision of the case. | |
Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955), was an important income tax case before the United States Supreme Court. The Court held as follows:
Two factually distinct cases were consolidated because they presented the same issue.
The Supreme Court, in an opinion by Chief Justice Earl Warren, held that the award of treble damages was taxable income.
In the opinion, Warren pointed out that the language of section 22(a) (the predecessor of current section 61(a)) was employed by Congress in order utilize "the full measure of its taxing power," as provided for under the Sixteenth Amendment. Essentially, Congress, in enacting section 22(a), intended to tax all gains except those specifically exempted.
The Court then held that the amounts received by the taxpayers in this case were "instances of undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion."
This three-part "test" for determining income is broader than the earlier test employed by the Court in Eisner v. Macomber, and is to this day the preferred test for identifying gross income.
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