Kalpana Kalpana (Editor)

Robertson v. United States

Updated on
Edit
Like
Comment
Share on FacebookTweet on TwitterShare on LinkedInShare on Reddit
Citations
  
343 U.S. 711 (more)

End date
  
1952

Dissent
  
Jackson

Full case name
  
Robertson v. United States

Majority
  
Douglas, joined by Black, Reed, Burton, Clark, Minton

People also search for
  
Bogardus v. Commissioner, Commissioner v. Duberstein, United States v. Comstock

Robertson v. United States, 343 U.S. 711 (1952), was a United States Supreme Court case in which the Court held that cash contest prizes are taxable, and attributable to the most-recent thirty-six months ending with the close of the year in which it was received.

Background

The facts of the case involve American composer Leroy Robertson entering a previously composed symphony, Trilogy, into a 1947 contest for musical compositions. Robertson won $25,000, claimed the prize on his income taxes as income attributable to the three years he wrote it (1937 through 1939), and thereafter claimed a refund that treated his winnings as a gift.

The case is notable, and thus appears in law school casebooks, for the following holdings:

  • A cash prize received by the winner of a contest in musical composition is "gross income" within the meaning of § 22(a) of the Internal Revenue Code, and it is not a "gift" excluded from gross income by § 22(b)(3). Pp. 343 U. S. 713-714.
  • In computing under § 107(b), the tax on such a cash prize for a musical composition, the income should be attributed to the 36 months ending with the close of the year in which it was received—not some earlier period of 36 months during which the taxpayer worked on the composition. Pp. 343 U. S. 714-716.

    • References

    Robertson v. United States Wikipedia
    (Text) CC BY-SA


    Similar Topics