United States v. Kaiser

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United States v. Kaiser
Seal of the United States Supreme Court.svg
Argued March 23, 1960
Decided June 13, 1960
Full case nameUnited States v. Kaiser
Citations363 U.S. 299 ( more )
80 S. Ct. 1204; 4 L. Ed. 2d 1233; 1960 U.S. LEXIS 1925; 60-2 U.S. Tax Cas. (CCH) ¶ 9517; 5 A.F.T.R.2d (RIA) 1611; 1960-2 C.B. 33; 46 L.R.R.M. 2350
Prior history262 F.2d 367 (affirmed)
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black  · Felix Frankfurter
William O. Douglas  · Tom C. Clark
John M. Harlan II  · William J. Brennan Jr.
Charles E. Whittaker  · Potter Stewart
Case opinions
PluralityBrennan, joined by Warren, Black, Douglas
ConcurrenceFrankfurter (in result), joined by Clark
ConcurrenceDouglas
DissentWhittaker, joined by Harlan, Stewart
Laws applied
Internal Revenue Code

United States v. Kaiser, 363 U.S. 299 (1960), was an income tax case before the United States Supreme Court.

Contents

Background

Union and non-union strikers were provided limited financial assistance by a union.

A trade union, also called a labour union or labor union (US), is an association of workers in a particular trade, industry, or company created for the purpose of securing improvement in pay, benefits, working conditions or social and political status through collective bargaining and working conditions through the increased bargaining power wielded by creation of a monopoly of the workers. The trade union, through its leadership, bargains with the employer on behalf of union members and negotiates labour contracts with employers. The most common purpose of these associations or unions is "maintaining or improving the conditions of their employment". This may include the negotiation of wages, work rules, complaint procedures, rules governing hiring, firing and promotion of workers, benefits, workplace safety and policies.

When a non-union taxpayer filed his tax form, he did not include the amount of the assistance in his gross income. The taxpayer paid the additional tax owed and after an administrative rejection of his refund claim, sued for the refund in the United States district court for the Eastern District of Wisconsin.

Taxpayer person or organization subject to a tax on income

A taxpayer is a person or organization subject to pay a tax. Taxpayers have an Identification Number, a reference number issued by a government to its citizens.

Gross income is all a person's receipts and gains from all sources, before any deductions. The adjective "gross", as opposed to "net", generally qualifies a word referring to an amount, value, weight, number, or the like, specifying that necessary deductions have not been taken into account.

United States Federal republic in North America

The United States of America (USA), commonly known as the United States or America, is a country composed of 50 states, a federal district, five major self-governing territories, and various possessions. At 3.8 million square miles, the United States is the world's third or fourth largest country by total area and is slightly smaller than the entire continent of Europe's 3.9 million square miles. With a population of over 327 million people, the U.S. is the third most populous country. The capital is Washington, D.C., and the largest city by population is New York City. Forty-eight states and the capital's federal district are contiguous in North America between Canada and Mexico. The State of Alaska is in the northwest corner of North America, bordered by Canada to the east and across the Bering Strait from Russia to the west. The State of Hawaii is an archipelago in the mid-Pacific Ocean. The U.S. territories are scattered about the Pacific Ocean and the Caribbean Sea, stretching across nine official time zones. The extremely diverse geography, climate, and wildlife of the United States make it one of the world's 17 megadiverse countries.

A jury found that the financial assistance was a gift, excluding it from income under § 102(a) of the Internal Revenue Code, but a judgment notwithstanding the verdict was granted to the government. Then a United States Court of Appeals for the Seventh Circuit reversed a district court's grant of a judgment notwithstanding the verdict against respondent taxpayer.

Jury sworn body of people convened to render a verdict officially submitted to them by a court, or to set a penalty or judgment

A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt or lack thereof in a crime. In Anglophone jurisdictions, the verdict may be guilty or not guilty. The old institution of grand juries still exists in some places, particularly the United States, to investigate whether enough evidence of a crime exists to bring someone to trial.

The Internal Revenue Code (IRC), formally the Internal Revenue Code of 1986, is the domestic portion of federal statutory tax law in the United States, published in various volumes of the United States Statutes at Large, and separately as Title 26 of the United States Code (USC). It is organized topically, into subtitles and sections, covering income tax, payroll taxes, estate taxes, gift taxes, and excise taxes; as well as procedure and administration. Its implementing agency is the Internal Revenue Service.

United States Court of Appeals for the Seventh Circuit

The United States Court of Appeals for the Seventh Circuit is a federal court with appellate jurisdiction over the courts in the following districts:

By a divided vote, the United States Court of Appeals for the Seventh Circuit reversed. 262 F.2d 367. It held alternatively that the assistance was not within the concept of income of § 61 (a) of the Code, and that in any event the jury's determination that the assistance was a gift, and hence excluded from gross income by § 102 (a), had rational support in the evidence and accordingly was within its province as trier of the facts.

The court granted the government's petition for certiorari, because of the importance of the issues presented. 359 U.S. 1010.

A government is the system or group of people governing an organized community, often a state.

A petition is a request to do something, most commonly addressed to a government official or public entity. Petitions to a deity are a form of prayer called supplication.

Certiorari, often abbreviated cert. in the United States, is a process for seeking judicial review and a writ issued by a court that agrees to review. A certiorari is issued by a superior court, directing an inferior court, tribunal, or other public authority to send the record of a proceeding for review.

Opinion of the Court

The Court upheld the appellate court's decision but declined to decide whether the assistance was a gift because the government did not object to the jury charge regarding the gift exclusion. The Court held that the proof was adequate to support the conclusion of the jury. The Court held that, in an allocation of power to decide the question, once it has been found that the decision could reasonably be reached on the evidence and the district court's instructions were not overthrown, the Court's reviewing authority was exhausted. The Court held that the jury was empowered to render the verdict that it did.

The United States Supreme Court affirmed the judgment below, six members of the Court agreeing that the jury had properly found that the strike assistance was an excludable gift. There was no opinion by a majority of the court. Brennan, J., announced the judgment of the court and delivered an opinion, sustaining excludability, in which he was joined by Warren, Ch. J., and Black and Douglas, JJ. In a separate opinion, Frankfurter, J., joined by Clark, J., concurred in the result. Douglas, J., filed a separate concurring opinion. Whittaker, J., dissented in an opinion in which he was joined by Harlan and Stewart, JJ

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