The Oyez Project: Federal Taxation Issues - Federal Taxation Decisions

American Automobile Assn. v. U.S.

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Aquilino v. United States

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Arkansas Best Corp. v. Commissioner

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Atlantic Mutual Ins. Co. v. IRS

Is the government's interpretation of reserve strengthening correct in determining property and casualty insurers' liability?

Yes. In a unanimous decision, announced by Justice Antonin Scalia, the Court ruled that the IRS interpretation of reserve strengthening seemed "reasonable accommodation." It was fair and unabusive. Furthermore, the language of the provision was broad enough to embrace all increases in the reserves.

Automobile Club v. Commissioner

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Badaracco v. Commissioner

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Baral v. United States

Are remittances of withholding tax and estimated income tax paid on the due date of the taxpayer's income tax return?

Yes. Justice Clarence Thomas delivered the opinion of the unanimous Court, which held that remittances of withholding tax and estimated income tax are paid on the due date of a calendar year taxpayer's income tax return. The Court concluded that the ceiling on Baral's requested credit was zero, because, rather than being paid within the look-back period, between February 1, 1990 and June 1, 1993, both the withholding and the estimated taxes had been paid on April 15, 1989. The decision means that the three-year time limit for seeking a refund begins running when someone's withholding and estimated tax payments are made to the government. The deadline does not depend on when the person's income tax return is filed, the court said.

Begier v. IRS

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Bingler v. Johnson

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Bob Jones University v. Simon

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Boeing Co. v. United States

Was Boeing Co. required to take into account expenses incurred for R&D in accordance with applicable Treasury regulations in calculating its "combined taxable income" for purposes of determining taxation with respect to its domestic international sales corporation and foreign sales corporation?

Yes. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that section 1.861-8(e)(3) is a proper exercise of the Secretary of the Treasury's rulemaking authority. The Court reasoned that the general regulation classifying all R&D as an indirect cost attributable to all export sales was not arbitrary as it provided consistent treatment for costs items used in computing domestic taxable income and combined taxable income. Justice Stevens wrote that the rule's "allocation of R&D expenditures to all products in a category even when specifically intended to improve only one or a few of those products is no more tenuous than the allocation of a chief executive officer's salary to every product that a company sells even when he devotes virtually all of his time to the development of an Edsel." Justice Clarence Thomas filed a dissenting opinion, in which Justice Antonin Scalia joined.

Braunstein v. Commissioner

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Bufferd v. Commissioner Of Internal Revenue

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Bulova Watch Co. v. United States

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Cammarano v. United States

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Central Illinois Public Serv. Co. v. United States

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Central Tablet Mfg. Co. v. United States

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Colonial Am. Life Ins. Co. v. Commissioner

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Colony, Inc., v. Commissioner

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Commissioner Of Internal Revenue v. Soliman

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Commissioner Of Internal Revenue v. Fink

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Commissioner Of Internal Revenue v. P. G. Lake, Inc.

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Commissioner Of Internal Revenue v. Key Stone Consolidated Industries, Inc.

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Commissioner Of Internal Revenue v. Schleier

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Commissioner Of Internal Revenue v. Acker

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Commissioner v. "Americans United" Inc.

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Commissioner v. Bilder

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Commissioner v. Bollinger

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Commissioner v. Brown

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Commissioner v. Clark

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Commissioner v. Duberstein.

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Commissioner v. Engle

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Commissioner v. Estate of Hubert

Does the cost of administering an estate necessarily reduce the allowed estate-tax deduction for assets left to a spouse or charity?

No. In an opinion authored by Justice Anthony M. Kennedy, the Court ruled that a taxpayer does not have to reduce the estate tax deduction for marital or charitable bequests by the amount of the administration expenses that were paid from income generated during administration by assets allocated to those bequests. "When income is used . . . to pay administration expenses, this does not require the estate tax deductions be diminished," wrote Justice Kennedy.

Commissioner v. First Security Bank Of Utah

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Commissioner v. Gillette Motor Co.

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Commissioner v. Gordon

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Commissioner v. Groetzinger

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Commissioner v. Hansen

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Commissioner v. Idaho Power Co.

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Commissioner v. Indianapolis Power & Light Co.

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Commissioner v. Kowalski

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Commissioner v. Lester

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Commissioner v. Lincoln Savings & Loan Assn.

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Commissioner v. Lobue

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Commissioner v. Lundy

Can the Tax Court award a refund of taxes paid more than two years prior to the date on which the Commissioner of Internal Revenue mailed the taxpayer a notice of deficiency, when, on the date the notice of deficiency was mailed, the taxpayer had not yet filed a return?

No. In a 7-2 opinion delivered by Justice Sandra Day O'Connor, the Court held that in these circumstances a 2-year look-back period applies and the Tax Court lacks jurisdiction to award a refund. Finding that the Tax Court properly applied the 2-year look-back period to Lundy's case, Justice O'Connor noted that Lundy's taxes were withheld from his wages such that they were deemed paid on the date his 1987 tax return was due, which is more than two years prior to the date the notice of deficiency was mailed. The Lundy was thus seeking a refund of taxes paid outside the applicable look-back period. Justices John Paul Stevens and Clarence Thomas filed dissents.

Commissioner v. Nat. Alfalfa Dehydrating

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Commissioner v. Noel Estate

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Commissioner v. Portland Cement Co. Of Utah

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Commissioner v. Southwest Expl. Co.

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Commissioner v. Standard Life & Acc. Ins. Co.

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Commissioner v. Stern

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Commissioner v. Stidger

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Commissioner v. Sullivan

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Commissioner v. Tellier

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Commissioner v. Tufts

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Corn Products Co. v. Commissioner

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Cory Corporation v. Sauber

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Cottage Savings Assoc. v. Commissioner of Internal Revenue

Can the exchange of properties considered "substantially identical" for accounting purposes under Federal Home Loan Bank Board regulations be considered a "disposition of property" for IRS tax purposes, given that properties exchanged must be materially different to constitute a "disposition" under section 1001(a) of Title 26 of the tax code?

Yes. In a 7-to-2 decision, the Supreme Court held that the definition of "substantially identical" under the FHLBB regulations was intentionally flexible and broad enough to include even properties that were "materially different" for IRS purposes. Justice Thurgood Marshall, in the majority opinion, wrote that exchanged properties are "materially different" if they "embody legally distinct entitlements." The properties involved in this exchange clearly satisfied that test. "Because the participation interests exchanged by Cottage Savings and the other S & L's derived from loans that were made to different obligors and secured by different homes, the exchanged interests did embody legally distinct entitlements. Consequently, we conclude that Cottage Savings realized its losses at the point of exchange."

Davis v. United States

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Dickman v. Commissioner

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Diedrich v. Commissioner

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Dixon v. United States

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Don E. Williams Co. v. Commissioner

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Donaldson v. United States

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Drye v. United States

Does an heir's interest to an estate constitute "property" or "rights to property" such that federal liens are valid against the heir's interest, even if the heir has disclaimed the interest under state law?

Yes. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that Drye's disclaimer did not defeat the federal tax liens. The Court read the Internal Revenue Code to look to state law for a delineation of a taxpayer's rights or interests, but to leave to federal law the determine whether those rights or interests constitute "property" or "rights to property" under section 6321. Justice Ginsburg wrote for the Court that "Drye had the unqualified right to receive the entire value of his mother's estate...or to channel that value to his daughter. The control rein he held under state law, we hold, rendered the inheritance 'property' or 'rights to property' belonging to him within the meaning of [section] 6321, and hence subject to the federal tax liens that sparked this controversy."

Enochs v. Williams Packing Co.

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Fidelity-Phila. Trust Co. v. Smith

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Flora v. United States

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Flora v. United States

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Frank Lyon Co. v. United States

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Fribourg Nav. Co. v. Commissioner

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Fulman v. United States

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Gitlitz v. Commissioner

Does the Internal Revenue Code permit taxpayers to increase bases in their S corporation stock by the amount of an S corporation's discharge of indebtedness excluded from gross income? If the Code permits such an increase, does the increase occur before taxpayers are required to reduce the S corporation's tax attributes?

Yes and yes. In an 8-1 opinion delivered by Justice Clarence Thomas, the Court held that excluded discharged debt is an "item of income," which passes through to shareholders and increases their bases in an S corporation's stock and that pass-through is performed before the reduction of an S corporation's tax attributes. Justice Thomas wrote that the Code "simply does not say that discharge of indebtedness ceases to be an item of income when the S corporation is insolvent. Instead it provides only that discharge of indebtedness ceases to be included in gross income." "In order to determine the 'tax imposed,' an S corporation shareholder must adjust his basis in his corporate stock and pass through all items of income and loss. Consequently, the attribute reduction must be made after the basis adjustment and pass-through," continued Justice Thomas.

Hanover Bank v. Commissioner

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Haynes v. United States

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Hernandez v. Commissioner

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Hertz Corp. v. United States

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Hillsboro National Bank v. Commissioner

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Holywell Corp. v. Smith

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Hoover Express Co. v. United States

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Indopco, Inc. v. Commissioner Of Internal Revenue

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Internal Revenue Commissioner v. Banks

Does a taxpayer's gross income from litigation proceeds include contingency fees paid to lawyers?

Yes. In a unanimous, 8-0 opinion delivered by Justice Anthony Kennedy, the Court held that if a litigant's recovery constituted income, the litigant's income included the contingency fee paid to his or her lawyer. The Court held that an economic gain assigned in advance to another party - as in a contingency-fee agreement - could not be excluded from gross income.

Ivan Allen Co. v. United States

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Jackson v. United States

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Jarecki v. G. D. Searle & Co.

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Jewett v. Commissioner

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Joint Industry Board v. U.S.

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Knetsch v. United States

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Libson Shops, Inc. v. Koehler

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Malat v. Riddell

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Massey Motors v. United States

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Maximov v. United States

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Meyer v. United States

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Meyer v. United States

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Millinery Corp. v. Commissioner

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Murdock Acceptance Corp. v. U.S.

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Nash v. United States

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National Lead Co. v. Commissioner

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National Muffler Dealers Assn. v. United States

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Newark Morning Ledger Co., As Successor To The Herald Co. v. United States

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Nicholas v. United States

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Northeastern Nat. Bank v. U.S.

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O'connor v. United States

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O'Gilvie v. United States

Does the exclusionary provision of 26 USC section 104(a)(2), which excludes from gross income the "amount of any damages received... on account of personal injuries or sickness," apply to punitive damages received by a plaintiff in a tort suit for personal injuries?

No. In a 6-3 opinion delivered by Justice Stephen G. Breyer, the Court held that the punitive damages received by the O'Gilvies were not received "on account of" personal injuries," and therefore the provision did not apply and the damages were taxable. Agreeing with the Government's definition, Justice Breyer reasoned that the exclusionary provision applied to those personal injury lawsuit damages that were awarded by reason of, or because of, the personal injuries, and not to punitive damages that do not compensate injury, but are private fines to punish and deter reprehensible conduct. Justice Antonin Scalia, who was joined by Justices Sandra Day O'Connor and Clarence Thomas, dissented.

Otte v. United States

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Paragon Coal Co. v. Commissioner

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Parsons v. Smith

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Paulsen v. Commissioner

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Peurifoy v. Commissioner

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Phelps v. United States

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Portland Golf Club v. Commissioner

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Putnam v. Commissioner

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Reisman v. Caplin

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Rowan Cos. v. United States

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Rudolph v. United States

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Ryan v. United States

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Schlude v. Commissioner

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Sims v. United States

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Slodov v. United States

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Small Business Adm'n v. McClellan

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Snow v. Commissioner

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Sorenson v. Secretary Of Treasury

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St. Martin Lutheran Church v. South Dakota

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Tank Truck Rentals v. Commissioner

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Thor Power Tool Co. v. Commissioner

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Tiffany Fine Arts, Inc. v. United States

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Turnbow v. Commissioner

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U.S. v. Anderson, Clayton & Co.

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U.S. v. Cannelton Sewer Pipe Co.

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U.S. v. Consolidated Edison Co.

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U.S. v. Durham Lumber Co.

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U.S. v. John Hancock Mut. Ins. Co.

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U.S. v. Manufacturers Nat. Bank

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U.S. v. Pioneer American Ins. Co.

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U.S. v. Union Central Life Ins. Co.

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United California Bank v. United States

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United Dominion Industries v. United States

Must an affiliated group of corporations' product liability loss be figured on a consolidated, single-entity basis?

Yes. In an 8-1 opinion delivered by Justice David H. Souter, the Court held that an affiliated group's product liability loss must be figured on a consolidated, single-entity basis, and not by aggregating product liability losses separately determined company by company. Justice Souter wrote for the Court that "'the Internal Revenue Code vests ample authority in the Treasury to adopt consolidated return regulations to effect a binding resolution of the question presented in this in this case.' To the extent that the Government has exercised that authority, its actions point to the single-entity approach as the better answer. To the extent the Government disagrees, it may amend its regulations to provide for a different one."

United States v. Noland

May a bankruptcy court subordinate government attempts to collect tax penalties?

No. In a unanimous decision, announced by Justice David H. Souter, the Court ruled that giving tax-penalty claims a lower priority than other claims contradicts Congress_ scheme of priorities regarding federal bankruptcy law.

United States By And Through Internal Revenue Service v. Mcdermott

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United States v. Allen-Bradley Co.

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United States v. American Bar Endowment

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United States v. American College of Physicians

Were advertisements for medical products in the American College of Physicians' medical journal "substantially related" to the organization's tax-exempt purpose of maintaining high standards in medicine, and therefore tax-exempt?

No. In a unanimous decision authored by Justice Thurgood Marshall, the Supreme Court held that the advertisements in this particular case were not "substantially related" to the medical journal's educational purposes. The Court found that the conduct of the journal, rather than the content of the advertisements, was the relevant factor. Quoting the Claims Court, Justice Marshall wrote, "The evidence is clear that plaintiff did not use the advertising to provide its readers a comprehensive or systematic presentation of any aspect of the goods or services publicized. Those companies willing to pay for advertising space got it; others did not." The Court rejected both the government's contention that all advertising revenue should be taxed and the journal's contention that any informative advertising revenue should be exempt, relying instead on a case-by-case examination.

United States v. Arthur Young & Co.

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United States v. Atlas Ins. Co.

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United States v. Basye

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United States v. Bess

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United States v. Bisceglia

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United States v. Boyle

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United States v. Brockamp

May courts toll, for nonstatutory reasons, the statutory time limitations for filing tax refund claims set forth in the Internal Revenue Code of 1986?

No. In a unanimous decision authored by Justice Stephen G. Breyer, the Court ruled that Congress did not intend the "equitable tolling" doctrine to apply to the Internal Revenue Code of 1986's time limitations for filing tax refund claims. Justice Breyer wrote that allowing such exceptions to the filing deadline "could create serious administrative problems by forcing the IRS to respond to, and perhaps litigate, large numbers of late claims."

United States v. Brosnan

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United States v. Buffalo Sa v. Bank

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United States v. Burke

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United States v. Byrum

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United States v. Calamaro

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United States v. Carlton

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United States v. Cartwright

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United States v. Catto

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United States v. Centennial Savings Bank

Can a bank list the exchange of properties that have equal fair market value as a loss on its federal Income Tax return if the property it loses is worth significantly less at the time of the exchange than it was when the property was initially acquired? May a bank treat money received from early withdrawal penalties as "income from the discharge ... of indebtedness" under 26 U.S.C. 108(a)(1)(C)?

Yes and no. On the exchanged mortgage question, the Supreme Court referred to a companion case, Cottage Savings Association v. Commissioner of Internal Revenue, 499 U.S. 554, decided at the same time, in holding that the mortgages exchanged were "materially different" and could therefore be deducted as losses.

On the question of early withdrawal penalties, however, the Court sided with the IRS. Justice Thurgood Marshall, writing for the majority, stated that income comes from the "discharge ... of indebtedness" only when it is the result of the forgiveness of an obligation to repay assumed by the debtor (in this case the bank) at the outset of the debtor-creditor relationship. Because the early withdrawal fee was stipulated in the contract agreed upon at the outset of the certificate of deposit agreements, its payment was not the forgiveness of any obligation on behalf of the bank but rather the fulfillment of an obligation on behalf of the creditor. The bank was therefore required to list the penalties as income.

United States v. Chicago, B. &. Q. R. Co.

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United States v. Cleveland Indians Baseball Co.

Is backpay subject to federal taxes, under the Federal Insurance Contributions Act and the Federal Unemployment Tax Act, based on the year the money should have been paid out?

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that back wages are subject to FICA and FUTA taxes by reference to the year the wages are in fact paid. "Although the regulations, like the statute, do not specifically address backpay, the Internal Revenue Service has consistently interpreted them to require taxation of back wages according to the year the wages are actually paid, regardless of when those wages were earned or should have been paid," wrote Justice Ginsburg for the Court. Justice Antonin Scalia filed an opinion concurring in the judgment.

United States v. Consumer Life Ins. Co.

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United States v. Correll

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United States v. Craft

Does a tenant by the entirety possess property or rights to property to which a federal lien may attach?

Yes. In a 6-3 opinion delivered by Justice Sandra Day O'Connor, the Court held that each tenant possesses individual rights in the estate sufficient to constitute "property" or "rights to property" for the purposes of the lien. By determining that Michigan law granted the husband the right to use the property, the right to receive income produced by it, the right to exclude others from it, the non-unilateral right to alienate the property, and the right of survivorship, Justice O'Connor reasoned that the rights Michigan law granted to the husband as a tenant by the entirety qualified as "property" or "rights to property" under section 6321 and, therefore, the federal tax lien could attach to the husband's property. Justice Antonin Scalia filed a dissenting opinion, in which Justice Clarence Thomas joined. Justice Thomas also filed a dissenting opinion, in which Justices Scalia and John Paul Stevens joined.

United States v. Dalm

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United States v. Davis

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United States v. Davis

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United States v. Donruss Co.

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United States v. Equitable Life

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United States v. Estate Of Donnelly

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United States v. Estate Of Grace

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United States v. Fior D'Italia, Inc.

Does the law, under which the Federal Insurance Contribution Act taxes are paid, authorize the IRS to assess a restaurant for FICA taxes based upon its aggregate estimate of all the tips that the restaurant's customers paid its employees?

Yes. In a 6-3 opinion delivered by Justice Stephen G. Breyer, the Court held that the law authorizes the IRS to use the aggregate estimation method. The Court reasoned that the law, by granting the IRS assessment authority, necessarily granted it the power to decide how to make that assessment within certain limits. In rejecting Fior D'Italia's reasonability arguments, the Court said the law does not require the IRS to determine total tip income by estimating each individual employee's tip income separately, then adding individual estimates together to create a total. Justice David H. Souter, with whom Justices Antonin Scalia and Clarence Thomas joined, dissented. The IRS's method "raises anomaly after anomaly, to the point that one has to suspect that the Government's practice is wrong," argued Justice Souter.

United States v. Foster Lumber Co.

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United States v. Galletti

To qualify for the 10-year extension in the statute of limitations, does the government need to assess - beyond just the partnership that owes money - each individual partner for the debt?

No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that the IRS' assessment against the partnership was sufficient to extend the statute of limitations by 10 years to collect the money from the partners themselves. The Internal Revenue Code does not require the government to make separate assessments of a single debt against people or entities secondarily liable in order to extend the statute of limitations. The statute of limitations extension is attached to the debt - without reference to the entities who owe the debt.

United States v. General Dynamics Corp.

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United States v. Generes

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United States v. Gilmore

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United States v. Goodyear Tire & Rubber Co.

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United States v. Hatter

Did Congress violate the Compensation Clause when it extended the Medicare and Social Security taxes to the salaries of sitting federal judges? If so, was the violation cured when Congress increased the salaries of all federal judges by an amount greater than the new taxes?

In a 6-1 opinion delivered by Justice Stephen G. Breyer, the Court held that the Compensation Clause prevents the government from collecting Social Security taxes from federal judges who held office before Congress extended those taxes to federal employees and that the Compensation Clause violation was not cured by the 1984 pay increase for federal judges. In a 5-2 split, the Court held that the Government could collect Medicare taxes from the same class of judges. On the Medicare question, Justice Breyer, wrote that "this Court has held that the Legislature cannot directly reduce judicial salaries even as part of an equitable effort to reduce all Government salaries. But a tax law, unlike a law mandating a salary reduction, affects compensation indirectly, not directly. And those prophylactic considerations that may justify an absolute rule forbidding direct salary reductions are absent here, where indirect taxation is at issue."

United States v. Hemme

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United States v. Hill Et ux.

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United States v. Hilton Hotels

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United States v. Hougham

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United States v. Hughes Properties, Inc.

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United States v. International Business Machines Corp.

May the federal government impose a tax on premiums that U.S. businesses pay foreign insurers for risks that could arise in this country?

No. In a 6-2 decision, announced by Justice Clarence Thomas, the Court ruled the tax did violate the Export Clause and was therefore unconstitutional.

United States v. Irvine

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United States v. Kaiser

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United States v. Key

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United States v. Kimbell Foods, Inc.

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United States v. Leslie Salt Co.

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United States v. Midland-Ross Corp.

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United States v. Mississippi Chemical Corp.

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United States v. Mitchell

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United States v. Moore

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United States v. Munoz-Flores

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United States v. National Bank Of Commerce

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United States v. O'malley

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United States v. Patrick

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United States v. Powell

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United States v. Price

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United States v. Ptasynski

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United States v. Randall

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United States v. Reorganized CF& I Fab. of UT

Is the Internal Revenue Code's 10% tax liability claim on any "accumulated funding deficiency" in pension plans an "excise tax" under the Bankruptcy Code? May the Government's tax claims be given a lower priority than competing claims by other creditors in bankruptcy proceedings?

No and no. In an opinion authored by Justice David H. Souter, the Court held that the Internal Revenue Code's 10% tax liability claim on any "accumulated funding deficiency" in pension plans, 26 U.S.C. Section 4971(a), does not create an excise tax under the Bankruptcy Code. Additionally, the Court held that the subordination of the Government's tax claim to those of other creditors was an error.

United States v. Rodgers

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United States v. Romani

Does the federal priority statute, 31 USC section 3713(a), require that that a federal tax claim be given preference over a judgment creditor's perfected lien on real property where such a preference is not authorized by the Federal Tax Lien Act of 1966?

No. In an opinion delivered by Justice John Paul Stevens, the Court held that section 3713(a) does not require that a federal tax claim be given preference over a judgment creditor's perfected lien on real property. Justice Stevens reasoned that section 3713(a) has been limited by Federal Tax Lien Act of 1966, which provides that says a federal lien for back taxes is not valid until the government files proper notice with state or local officials. Accordingly, Justice Stevens wrote that the Tax Lien Act "represents Congress' detailed judgment as to when the Government's claims for unpaid taxes should yield to many different sorts of interests... in many different types of property... specifically crafted for tax collection purposes." Justice Antonin Scalia filed an opinion concurring in part and concurring in the judgment.

United States v. Ron Pair Enterprises, Inc.

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United States v. Skelly Oil Co.

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United States v. Sotelo

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United States v. Speers

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United States v. Stapf

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United States v. Swank

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United States v. Thompson/Center Arms Co.

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United States v. United States Shoe Corp.

Does the Harbor Maintenance Tax, as applied to goods loaded at U.S. ports for export, violate the Export Clause?

Yes. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that "the [Harbor Maintenance Tax], which is imposed on an ad valorem basis, is not a fair approximation of services, facilities, or benefits furnished to the exporters, and therefore does not qualify as a permissible user fee." The Court noted that the Export Clause does not categorically bar Congress from imposing any tax on exports and that a charge designed as compensation for government-supplied services, facilities, or benefits would pass scrutiny.

United States v. Vermont

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United States v. Vogel Fertilizer Co.

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United States v. Webb, Inc.

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United States v. Wells Fargo Bank

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United States v. Williams

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United States v. Zacks

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Waterman S. S. Corp. v. U.S.

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Whipple v. Commissioner

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Woodward v. Commissioner

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Zenith Radio Corp. v. United States

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