Commissioner v. Wodehouse
Commissioner v. Wodehouse, 337 U.S. 369 (1949), was a United States Supreme Court case in which the Court held that lump sums paid in advance by publications to non-resident aliens are taxable income under the Revenue Act and are indistinguishable from "royalties" paid over time within the meaning of that Act.[1]
Commissioner v. Wodehouse | |
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Argued December 10–13, 1948 Decided June 13, 1949 | |
Full case name | Commissioner v. Wodehouse |
Citations | 337 U.S. 369 (more) 69 S. Ct. 1120; 93 L. Ed. 1419; 81 U.S.P.Q. 482 |
Case history | |
Prior | Wodehouse v. Commissioner, 8 T.C. 637 (1947); reversed, 166 F.2d 986 (4th Cir. 1948); cert. granted, 335 U.S. 807 (1948). |
Subsequent | Rehearing denied, 338 U.S. 840 (1949). |
Holding | |
Lump sums paid in advance by publications to non-resident aliens are taxable income under the Revenue Act and are indistinguishable from "royalties" paid over time within the meaning of that Act. | |
Court membership | |
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Case opinions | |
Majority | Burton |
Dissent | Frankfurter, joined by Murphy, Jackson |
Laws applied | |
Revenue Act of 1934, Revenue Act of 1936 |
External links
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