Robertson v. United States

Robertson v. United States
Argued March 31, 1952
Decided June 2, 1952
Full case name Robertson v. United States
Citations 343 U.S. 711 (more)
72 S.Ct. 994; 96 L.Ed. 1237; 1952 U.S. LEXIS 2809
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.
Laws applied
Internal Revenue Code

Robertson v. United States, 343 U.S. 711 (1952),[1], was a United States Supreme Court case in which the Court held that cash contest prizes are taxable, and attributable to the most-recent thirty-six months ending with the close of the year in which it was received.

Background

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).[2]
  • 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.[3]

References

  1. ↑ Robertson v. United States, 343 U.S. 711 (1952).
  2. ↑ Robertson, 343 U. S. at 713-714.
  3. ↑ Robertson, 343 U.S. at 714-716.
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