Commissioner v. Glenshaw Glass Co.

Holding

Punitive damages received in a private antitrust suit are taxable income under the broad definition of gross income.

Facts

Glenshaw Glass received punitive damages in a private antitrust action and excluded them from gross income, arguing they were not 'gain' within Eisner v. Macomber.

Reasoning

Chief Justice Warren established the broad definition of gross income as 'accessions to wealth, clearly realized, and over which the taxpayers have complete dominion.' This definition explicitly displaced the narrower Eisner v. Macomber test for purposes of Section 61.