Commissioner v. Glenshaw Glass Co.

Commissioner v. Glenshaw Glass Co.
Supreme Court of the United States
Argued February 28, 1955 Decided March 28, 1955
Full case name	Commissioner of Internal Revenue v. Glenshaw Glass Company
Citations	348 U.S. 426 (more) 75 S. Ct. 473; 99 L. 483; 1955 U.S. LEXIS 1508; 55-1 U.S. Tax Cas. (CCH) ¶ 9308; 47 A.F.T.R. (P-H) 162; 1955-1 C.B. 207
Case history
Prior	Glenshaw Glass Co. v. Comm'r, 18 T.C. 860 (1952); William Goldman Theatres, Inc. v. Comm'r, 19 T.C. 637 (1953); affirmed, Comm'r v. Glenshaw Glass Co., 211 F.2d 928 (3d Cir. 1954); cert. granted, 348 U.S. 813 (1954).
Subsequent	Rehearing denied, 349 U.S. 925 (1955).
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
Chief Justice Earl Warren Associate Justices Hugo Black · Stanley F. Reed Felix Frankfurter · William O. Douglas Harold H. Burton · Tom C. Clark Sherman Minton · John M. Harlan II
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.
Laws applied
Internal Revenue Code

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Commissioner of Internal Revenue v. Glenshaw Glass Company

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:

• Congress, in enacting income taxation statutes that comprehend "gains or profits and income derived from any source whatever," intended to tax all gain except that which was specifically exempted.
• Income is not limited to "the gain derived from capital, from labor, or from both combined."

• Although the Court used this characterization in Eisner v. Macomber, it "was not meant to provide a touchstone to all future gross income questions."

• Instead, income is realized whenever there are "instances of [1] undeniable accessions to wealth, [2] clearly realized, and [3] over which the taxpayers have complete dominion."

• Under this definition, punitive damages qualify as "income" -- even though they are not derived from capital or from labor.^[1]