Commissioner v. Glenshaw Glass Co.

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Commissioner v. Glenshaw Glass Co.

Supreme Court of the United States

Argued February 28, 1955
Decided March 28, 1955


Full case name:	Commissioner of Internal Revenue v. Glenshaw Glass Company

Citations:	348 U.S. 426; 75 S. Ct. 473; 99 L. Ed. 483; 1955 U.S. LEXIS 1508; 55-1 U.S. Tax Cas. (CCH) P9308; 47 A.F.T.R. (P-H) 162; 1955-1 C.B. 207

Prior history:	Certiorari to the United States Court of Appeals for the Third Circuit

Holding

The Court held that Congress, in enacting the income taxation statutes, intended to tax all gain except that which was specifically exempted.

Court membership

Chief Justice: Earl Warren
Associate Justices: Hugo Black, Stanley Forman Reed, Felix Frankfurter, William O. Douglas, Harold Hitz Burton, Tom C. Clark, Sherman Minton, John Marshall Harlan II

Case opinions

Majority by: Warren
Joined by: Black, Reed, Franfurter, Burton, Clark, Minton
Dissent by: Douglas
Harlan took no part in the consideration or decision of the case.

Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955)^[1], was a case in which the United States Supreme Court held that Congress, in enacting the income taxation statutes, intended to tax all gain except that which was specifically exempted.

[edit] Facts

The defendant Glenshaw Glass Company had won an award of treble damages in an antitrust lawsuit. The defendant did not declare this award as income or pay taxes on it, claiming that it was not subject to taxation. The Internal Revenue Service brought suit to collect the tax.

[edit] Opinion of the Court

The Supreme Court, in an opinion by Chief Justice Earl Warren, held that the award of treble damages was taxable income, and indeed that any gain from any source was taxable income, because it was an accession to wealth, unless Congress had specifically exempted such gain in the tax code.