taxable income
Definitions from Case Law · United States Supreme Court
Definitions from Case Law
From 281 U.S. 376 - Corliss v. Bowers · 1930Most cited · 1,698 citing opinions
The income that is subject to a man's unfettered command and that he is free to enjoy at his own option may be taxed to him as his income, whether he sees fit to enjoy it or not.
How the Supreme Court has restated “taxable income”
Each Supreme Court definition of “taxable income,” sized by how often later courts cited it. “Change” is measured by wording overlap with earlier definitions — a rough signal, not a semantic judgment.
How often courts cite the cases defining “taxable income”
Court decisions citing the 3 opinions that defined “taxable income” — 3,348 in all, by decade. Counts are citations to the defining cases as a whole, not verified uses of the term. The dip in the most recent years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the latest years.
All 3 definitions, chronological · 1930–1952
The very essence of taxable income, as that concept is used in Section 22(a), is the accrual of some gain, profit or benefit to the taxpayer.
An unlawful gain, as well as a lawful one, constitutes taxable income when its recipient has such control over it that, as a practical matter, he derives readily realizable economic value from it. That occurs when cash, as here, is delivered by its owner to the taxpayer in a manner which allows the recipient freedom to dispose of it at will, even though it may have been obtained by fraud and his freedom to use it may be assailable by someone with a better title to it.
unlawful gains