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

Name: Robertson v. United States, 343 U.S. 711 (1952) - Syllabus
Author: U.S. Supreme Court

Robertson v. United States

No. 388

Argued March 31, 1952
Decided June 2, 1952
343 U.S. 711

CERTIORARI TO THE UNITED STATES COURT OF APPEALS

FOR THE TENTH CIRCUIT

Syllabus

1. 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. 713-714.

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. Pp. 714-716.

190 F.2d 680 affirmed.

The District Court held that a cash prize received by the winner of a contest in musical composition was a gift exempted from taxation by § 22(b)(3) of the Internal Revenue Code. 93 F.Supp. 660. The Court of Appeals reversed. 190 F.2d 680. This Court granted certiorari. 342 U.S. 896. Affirmed, p. 716.

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Chicago: U.S. Supreme Court, "Syllabus," Robertson v. United States, 343 U.S. 711 (1952) in 343 U.S. 711 Original Sources, accessed May 7, 2025, http://www.originalsources.com/Document.aspx?DocID=891JMU3KJ6TMR1S.

MLA: U.S. Supreme Court. "Syllabus." Robertson v. United States, 343 U.S. 711 (1952), in 343 U.S. 711, Original Sources. 7 May. 2025. http://www.originalsources.com/Document.aspx?DocID=891JMU3KJ6TMR1S.

Harvard: U.S. Supreme Court, 'Syllabus' in Robertson v. United States, 343 U.S. 711 (1952). cited in 1952, 343 U.S. 711. Original Sources, retrieved 7 May 2025, from http://www.originalsources.com/Document.aspx?DocID=891JMU3KJ6TMR1S.

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