Robertson v. United States

Supreme Court of the United States

Argued March 31, 1952
Decided June 2, 1952

Full case name

Robertson v. United States

Holding

That cash contest prizes are taxable, and attributable to the most-recent 36 months ending with the close of the year in which it was received

Court membership

Chief Justice Fred M. Vinson

Associate Justices Hugo Black · Stanley F. Reed Felix Frankfurter · William O. Douglas Robert H. Jackson · Harold H. Burton Tom C. Clark · Sherman Minton

Case opinions

Majority

Douglas, joined by Black, Reed, Burton, Clark, Minton

Dissent

Jackson

Frankfurter took no part in the consideration or decision of the case.

not to be confused with United States v. Robertson, 514 U.S. 669 (1995)

Robertson v. United States, 343 U.S. 711 (1952),^[1] was an income tax case before the U.S. Supreme Court discussing, under United States tax law, whether prizes are exempt as gifts under §102(a).

The facts of the case involve American composer Leroy Robertson entering a previously composed symphony, Trilogy, into a 1947 contest for musical compositions. Robertson won $25,000, claimed the prize on his income taxes as income attributable to the three years he wrote it (1937 through 1939), and thereafter claimed a refund that treated his winnings as a gift.

The case is notable, and thus appears in law school casebooks, for the following holdings:

A cash prize received by the winner of a contest in musical composition is "gross income" within the meaning of § 22(a) of the Internal Revenue Code, and it is not a "gift" excluded from gross income by § 22(b)(3). Pp. 343 U. S. 713-714.

In computing under § 107(b), the tax on such a cash prize for a musical composition, the income should be attributed to the 36 months ending with the close of the year in which it was received -- not some earlier period of 36 months during which the taxpayer worked on the composition. Pp. 343 U. S. 714-716.

References

^ Robertson v. United States, 343 U.S. 711 (1952).