income
Definitions from Case Law · United States Supreme Court
Definitions from Case Law
From 279 U.S. 716 - Old Colony Trust Co. v. Commissioner · 1929Most cited · 1,790 citing opinions
third-party discharge of tax obligation
The discharge by a third person of an obligation to him is equivalent to receipt by the person taxed.
How the Supreme Court has restated “income”
Each Supreme Court definition of “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 “income”
Court decisions citing the 10 opinions that defined “income” — 4,500 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 10 definitions, chronological · 1924–1942
- ORIGINAL
mere change for purposes of reorganization in the technical ownership of an enterprise, under circumstances like those here disclosed, followed by issuance of new certificates constitutes gain separated from the original capital interest. Something more is necessary—something which gives the stockholder a thing really different from what he theretofore had.
corporate reorganization
The subsidy payments taxed were not made for services rendered or to be rendered. They were not profits or gains from the use or operation of the railroad, and do not constitute income within the meaning of the Sixteenth Amendment.
Income may be defined as gain derived from capital, from labor, or from both combined, including profit gained through sale or conversion of capital.
Income may be defined as the gain derived from capital, from labor, or from both combined, provided it be understood to include profit gained through a sale or conversion of capital assets.
increase in value of property, not realized as gain by its sale or other disposition . . . is nevertheless a gain from capital investment which, when realized, by conversion into money or other property, constitutes profit which has consistently been regarded as income within the meaning of the Sixteenth Amendment and taxable as such in the period when realized.
The rental value of the building used by the owner does not constitute income within the meaning of the Sixteenth Amendment.
Income within the meaning of the Sixteenth Amendment is the fruit that is born of capital, not the potency of fruition.
The discharge of liability by the payment of the Hendler Company's indebtedness constituted income to the Hendler Company and is to be treated as such.
discharge of indebtedness
Payments made directly to shareholders by the lessee or transferee of corporate property are properly recognized as income to the corporation by reason of the relationship of a corporation to its shareholders. The fact that there is an anticipatory arrangement whereby the taxpayer is not even a conduit of the payments is no more significant in this type of case than it was in Lucas v. Earl.