Robertson v. United States, 343 U.S. 711 (1952), 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.[1]
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,[citation needed] 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]
robertson, united, states, this, article, relies, excessively, references, primary, sources, please, improve, this, article, adding, secondary, tertiary, sources, find, sources, news, newspapers, books, scholar, jstor, november, 2019, learn, when, remove, this. This article relies excessively on references to primary sources Please improve this article by adding secondary or tertiary sources Find sources Robertson v United States news newspapers books scholar JSTOR November 2019 Learn how and when to remove this template message Robertson v United States 343 U S 711 1952 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 1 Robertson v United StatesSupreme Court of the United StatesArgued March 31 1952Decided June 2 1952Full case nameRobertson v United StatesCitations343 U S 711 more 72 S Ct 994 96 L Ed 1237 1952 U S LEXIS 2809Case historyPriorJudgment for plaintiff 93 F Supp 660 D Utah 1950 reversed 190 F 2d 680 10th Cir 1951 cert granted 342 U S 896 1951 HoldingThat cash contest prizes are taxable and attributable to the most recent 36 months ending with the close of the year in which it was receivedCourt membershipChief Justice Fred M Vinson Associate Justices Hugo Black Stanley F ReedFelix Frankfurter William O DouglasRobert H Jackson Harold H BurtonTom C Clark Sherman MintonCase opinionsMajorityDouglas joined by Black Reed Burton Clark MintonDissentJacksonFrankfurter took no part in the consideration or decision of the case Laws appliedInternal Revenue CodeBackground editThe 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 citation needed 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 edit Robertson v United States 343 U S 711 1952 Robertson 343 U S at 713 714 Robertson 343 U S at 714 716 External links editText of Robertson v United States 343 U S 711 1952 is available from CourtListener Findlaw Google Scholar Justia Library of Congress nbsp This article related to the Supreme Court of the United States is a stub You can help Wikipedia by expanding it vte nbsp This tax related article is a stub You can help Wikipedia by expanding it vte Retrieved from https en wikipedia org w index php title Robertson v United States amp oldid 1175149173, wikipedia, wiki, book, books, library,
