Cases Explained
CASE LINKS: SIGNIFICANCE: These two cases present the question of whether the constitutional power of excise taxation over property located outside United States the country applies in two scenarios: The court decided that the domiciled taxpayer was liable and the taxpayer with the foreign domicile was not liable. The circumstances of the Goelet case most…
Case Link: https://scholar.google.com/scholar_case?case=11404527107386030954 Wikipedia Article: https://en.wikipedia.org/wiki/Commissioner_v._Glenshaw_Glass_Co. IMPORTANCE: This case is famous because it redefined “gross income” for the purposes of I.R.C. 61 to mean “all accessions of wealth over which the taxpayer has complete dominion”. Prior to this case, Stratton’s Independence v. Howbert, 231 U.S. 399, 415, 34 S.Sup.Ct. 136, 140 58 L.Ed. 285, Doyle v.…
This is one of the VERY few cases that explains the meaning of the term “United States”. It is thus extremely important in discerning WHICH “United States” is meant in the context of the Internal Revenue Code. This case dealt with EXTERNAL excise taxation of imports under Article 1, Section 8, Clause 1 of the…
LINK: https://scholar.google.com/scholar_case?case=3081110958181951212 SIGNIFICANCE: George Springer reaped interest income from United States bonds. So he was not difficult for the Collector to locate to demand that Springer file a return and pay tax on that. Springer followed the instructions on the form and reported not only his interest from U.S. bonds but also his professional fees he…
LINK TO CASE: https://scholar.google.com/scholar_case?case=2852002685220457827 SIGNIFICANCE: Declared the first income tax instituted to fund the Civil War, the Revenue Act of 1861, 122 Stat. 292 unconstitutional. Ruled that Congress can TAX but cannot “authorize” (meaning LICENSE) the thing subject to tax within the constitutional states of the Union. This case also recognized the ability of the…
LINK TO CASE: https://scholar.google.com/scholar_case?case=7292056596996651119 WIKIPEDIA: https://en.wikipedia.org/wiki/Pollock_v._Farmers%27_Loan_%26_Trust_Co. SIGNIFICANCE: This was the first attempt after the civil war to implement an income tax. It was declared unconstitutional because it was a direct, unapportioned tax upon real property. In this case the Supreme Court found an 1884 tax law similar to the 1864 Tax Law in the Sprinter…
SOURCE: https://www.irs.gov/privacy-disclosure/the-truth-about-frivolous-arguments-section-i-a-to-c#contentionc2 IRS STATEMENT: C. The Meaning of Certain Terms Used in the Internal Revenue Code 2. Contention: The “United States” consists only of the District of Columbia, federal territories, and federal enclaves Some individuals and groups argue that the United States consists only of the District of Columbia, federal territories (e.g., Puerto Rico, Guam,…
SOURCE: https://www.irs.gov/privacy-disclosure/the-truth-about-frivolous-arguments-section-i-a-to-c#contentionc1 IRS STATEMENT: C. The Meaning of Certain Terms Used in the Internal Revenue Code 1. Contention: Taxpayer is not a “citizen” of the United States and thus is not subject to the federal income tax laws. Some individuals argue that they have rejected citizenship in the United States in favor of state citizenship;…