Court index
Supreme Court tax cases
Seeded tax cases from the Supreme Court in United States.
Country
United States
Court
Supreme Court
Cases
42
2022
Boechler, P.C. v. Commissioner
596 U.S. 199 (2022)
The 30-day deadline for petitioning the Tax Court for review of a Collection Due Process determination is a non-jurisdictional claim-processing rule subject to equitable tolling.
2021
CIC Services, LLC v. Internal Revenue Service
593 U.S. 209 (2021)
The Anti-Injunction Act does not bar a pre-enforcement challenge to an IRS reporting requirement that is enforced by a separate tax penalty.
2012
United States v. Home Concrete & Supply, LLC
566 U.S. 478 (2012)
Overstatement of basis is not an omission from gross income that triggers the extended six-year statute of limitations under section 6501(e)(1)(A); the three-year limitations period applies, and a contrary Treasury regulation cannot override Colony Inc. v. Commissioner.
2011
Mayo Foundation for Medical Education and Research v. United States
562 U.S. 44 (2011)
Treasury Regulations are entitled to Chevron deference; the prior National Muffler standard does not apply uniquely to tax regulations.
1993
Commissioner v. Soliman
506 U.S. 168 (1993)
A home office qualifies as the taxpayer's principal place of business under section 280A only when the relative importance of activities and the time spent there make it the most important location of the business, considered as a whole.
1992
INDOPCO, Inc. v. Commissioner
503 U.S. 79 (1992)
Expenses incurred in a friendly takeover that produce significant long-term benefits must generally be capitalized rather than deducted as ordinary and necessary expenses.
1991
Cottage Savings Association v. Commissioner
499 U.S. 554 (1991)
A loss is realized when exchanged properties are materially different, even if they are economically similar in broad market terms.
1990
Commissioner v. Indianapolis Power & Light Co.
493 U.S. 203 (1990)
Customer security deposits subject to repayment on stated conditions are not gross income to the utility when received.
1988
Commissioner v. Bollinger
485 U.S. 340 (1988)
A corporation can be disregarded as the owner's true agent for federal tax purposes when the relationship is genuine in both form and substance rather than a dressed-up ownership arrangement.
1987
Commissioner v. Groetzinger
480 U.S. 23 (1987)
A taxpayer who pursued gambling full time, regularly, and for livelihood was engaged in a trade or business.
1983
Commissioner v. Tufts
461 U.S. 300 (1983)
On disposition of property subject to nonrecourse debt, the full unpaid balance of the debt is included in the amount realized even if it exceeds the fair market value of the property.
1978
Frank Lyon Co. v. United States
435 U.S. 561 (1978)
A sale-and-leaseback transaction with genuine economic substance and business purpose will be respected for tax purposes; the test looks at the multi-party realities and obligations of the transaction.
1967
United States v. Correll
389 U.S. 299 (1967)
Travel meal expenses are deductible only when the travel involves an overnight stay or other rest period requiring the taxpayer to be away from home.
1966
Commissioner v. Tellier
383 U.S. 687 (1966)
Legal expenses incurred to defend a business operator against criminal prosecution for activities related to the business are generally deductible as ordinary and necessary expenses.
1962
United States v. Davis
370 U.S. 65 (1962)
Transfer of appreciated property to a former spouse in satisfaction of marital property rights is a taxable disposition recognized at fair market value.
1961
James v. United States
366 U.S. 213 (1961)
Embezzled funds are includible in gross income in the year received notwithstanding an obligation to repay.
1960
Knetsch v. United States
364 U.S. 361 (1960)
Interest paid on a sham annuity-loan arrangement that lacks economic substance is not deductible.
1958
Commissioner v. Sullivan
356 U.S. 27 (1958)
Rent and wage payments by an illegal gambling business are ordinary and necessary business expenses deductible under Section 162.
1955
Commissioner v. Glenshaw Glass Co.
348 U.S. 426 (1955)
Punitive damages received in a private antitrust suit are taxable income under the broad definition of gross income.
1952
Arrowsmith v. Commissioner
344 U.S. 6 (1952)
Losses incurred by shareholders in satisfying transferee liability after the corporation's liquidation must be characterized as capital losses because they arise from the same transaction that produced the original capital gain.
1951
United States v. Lewis
340 U.S. 590 (1951)
Income received under a claim of right and reported in the year of receipt is not recomputed in that earlier year when later repaid; the taxpayer's remedy is a deduction in the year of repayment, not reopening of the prior year.
1950
United States v. Cumberland Public Service Co.
338 U.S. 451 (1950)
When shareholders, not the corporation, genuinely negotiate the sale of distributed assets after a bona fide liquidation, the gain is recognized at the shareholder level and not attributed back to the corporation.
1949
National Carbide Corp. v. Commissioner
336 U.S. 422 (1949)
A corporation formed or operated for business purposes must bear its own tax consequences, and a wholly owned subsidiary is not ignored merely because it claims to act as its parent's agent.
1947
Crane v. Commissioner
331 U.S. 1 (1947)
A property owner's basis includes nonrecourse debt encumbering the property, and on disposition the amount realized includes the unpaid principal of that debt.
1945
Commissioner v. Court Holding Co.
324 U.S. 331 (1945)
When a corporation negotiates a sale and then liquidates, distributing the asset to its shareholders who promptly close the same sale, the sale is properly attributed to the corporation for tax purposes under the substance-over-form doctrine.
1943
Moline Properties, Inc. v. Commissioner
319 U.S. 436 (1943)
A corporation remains a separate taxable entity when it was formed for a business purpose or actually carried on business activity.
1941
Higgins v. Commissioner
312 U.S. 212 (1941)
Managing one's own investments, even extensively, did not amount to carrying on a trade or business for the deduction sought.
1940
Helvering v. Eubank
311 U.S. 122 (1940)
An insurance agent who assigns renewal commissions earned but not yet payable to another person remains taxable on those commissions when paid because they were earned through his personal services.
1940
Helvering v. Horst
311 U.S. 112 (1940)
A donor who detaches and gifts interest coupons from bonds he retains is taxable on the interest when paid to the donee; the donor's exercise of dominion to direct payment to another realizes the income.
1940
Helvering v. Bruun
309 U.S. 461 (1940)
A landlord realizes taxable income upon repossession of leased property when the lessee has constructed improvements that increase the property's value, even though no cash or severable property is received.
1940
Deputy v. du Pont
308 U.S. 488 (1940)
The claimed expenditures were not deductible as ordinary and necessary business expenses of the taxpayer's own business.
1935
Gregory v. Helvering
293 U.S. 465 (1935)
A transaction that fits the literal words of the reorganization statute but lacks any real business or corporate purpose apart from tax avoidance is not respected as a tax-free reorganization.
1933
Welch v. Helvering
290 U.S. 111 (1933)
Payments made to creditors of a discharged bankruptcy debtor with whom the taxpayer was associated were capital expenditures rather than ordinary business expenses.
1932
North American Oil Consolidated v. Burnet
286 U.S. 417 (1932)
Income received under a claim of right without restriction on disposition is taxable in the year received, even if the taxpayer's right to retain it remains the subject of pending litigation.
1931
United States v. Kirby Lumber Co.
284 U.S. 1 (1931)
Cancellation of debt for less than its face amount generally produces taxable income to the debtor equal to the discount realized.
1931
Burnet v. Logan
283 U.S. 404 (1931)
When the value of contractual rights to receive future payments cannot be ascertained with reasonable accuracy, the transaction is open and the taxpayer may recover basis before recognizing gain (the open-transaction doctrine).
1931
Burnet v. Sanford & Brooks Co.
282 U.S. 359 (1931)
The federal income tax operates on an annual accounting basis; a litigation recovery in a later year compensating for prior-year losses is gross income in the year received, not netted against the earlier losses.
1930
Poe v. Seaborn
282 U.S. 101 (1930)
Spouses domiciled in a community property state may each report one-half of community income on their separate federal returns, because each spouse has a vested ownership interest in community income under state law.
1930
Corliss v. Bowers
281 U.S. 376 (1930)
A grantor who retains the power to revoke a trust and recover the trust property at will is taxable on the trust's income, because the power to dispose of income is the equivalent of ownership.
1930
Lucas v. Earl
281 U.S. 111 (1930)
Income from personal services is taxable to the person who earns it; a contract assigning future earnings to another person does not shift the income tax liability to the assignee.
1929
Old Colony Trust Co. v. Commissioner
279 U.S. 716 (1929)
An employer's payment of an employee's income tax is itself additional compensation and is taxable to the employee as gross income.
1920
Eisner v. Macomber
252 U.S. 189 (1920)
A pro rata stock dividend representing a mere change in the form of ownership of the same accumulated surplus does not constitute taxable income within the meaning of the Sixteenth Amendment.
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.