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Supreme Court cases

Case detail

Commissioner v. Indianapolis Power & Light Co.

493 U.S. 203 (1990)

Court

Supreme Court

Date

1990-01-09

Outcome

for-taxpayer

Holding

Customer security deposits subject to repayment on stated conditions are not gross income to the utility when received.

Facts

Indianapolis Power & Light required certain customers to provide refundable deposits. The IRS argued the deposits were income upon receipt.

Reasoning

Justice Blackmun emphasized the 'complete dominion' standard from Glenshaw Glass. Because IP&L's right to keep the deposits was contingent on customer behavior and the company recognized a liability to refund them, the company did not have complete dominion at receipt.

Case metadata

Jurisdiction: United States
Topics: gross income, claim of right, security deposits
Statutes applied: 26 U.S.C. 61

Official opinion

Open official decision

Cases cited

Commissioner v. Glenshaw Glass Co.

348 U.S. 426 (1955)

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