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Irwin v. Gavit, 268 U.S. 161 (1925)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Irwin v. Gavit, 268 U.S. 161 (1925)
Irwin v. Gavit No. 325 Argued April 15, 1925 Decided April 27, 1925 268 U.S. 161
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE SECOND CIRCUIT
Syllabus
1. A will provided that the income from a fund in trust should be applied to the education and support of the testator’s granddaughter so far as the trustees deemed proper, and that the balance of it should be divided into two equal parts, one of which should be paid to the plaintiff in equal, quarter-yearly installments during his life. On the granddaughter’s reaching the age of twenty-one or dying, the fund was to go over, so that, considering her age, the plaintiff’s interest could not exceed fifteen years. Held that the sums paid the plaintiff were taxable income within the meaning of the Constitution, and of the Income Tax Act of October 3, 1913, which taxed "the entire net income arising or accruing . . . to every citizen of the United States" and defined net income as
gains or profits and income derived from any source whatever, including the income from but not the value of property acquired by gift, bequest, devise, or descent.
P. 166.
2. The provision of the above act exempting bequests assumes the gift of a corpus, and contrasts it with the income arising from it, but was not intended to exempt income, properly so called, simply because of a severance between it and the principal fund. P. 167.
3. The rule that tax laws shall be construed favorably for the taxpayers is not a reason for creating or exaggerating doubts of their meaning. P. 168.
295 F. 84 reversed.
Certiorari to a judgment of the Circuit Court of Appeals affirming a judgment for the plaintiff in an action to recover taxes and penalties exacted under an income tax law. See 275 F. 643.
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Chicago: U.S. Supreme Court, "Syllabus," Irwin v. Gavit, 268 U.S. 161 (1925) in 268 U.S. 161 268 U.S. 165. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=L56T54DQDG1FJ3V.
MLA: U.S. Supreme Court. "Syllabus." Irwin v. Gavit, 268 U.S. 161 (1925), in 268 U.S. 161, page 268 U.S. 165. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=L56T54DQDG1FJ3V.
Harvard: U.S. Supreme Court, 'Syllabus' in Irwin v. Gavit, 268 U.S. 161 (1925). cited in 1925, 268 U.S. 161, pp.268 U.S. 165. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=L56T54DQDG1FJ3V.
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