Goodrich v. Edwards, 255 U.S. 527 (1921)

Goodrich v. Edwards


No. 663


Argued March 10, 11, 1921
Decided March 28, 1921
255 U.S. 527

ERROR TO THE DISTRICT COURT OF THE UNITED STATES
FOR THE SOUTHERN DISTRICT OF NEW YORK

Syllabus

1. Profit realized upon the sale of stocks held as an investment is income, and so much of it as accrued after March 1, 1913, is taxable under the Income Tax Laws of 1916, 1917, and the Sixteenth Amendment. P. 534. Merchants’ Loan & Trust Co. v. Smietanka, ante,509.

2. The statute imposes the income tax on the proceeds of a sale of personal property to the extent only that gains are derived therefrom by the vendor, and § 2(c) is applicable only where a gain over the original capital investment has been realized after March 1, 1913. P. 535.

Reversed in part, affirmed in part.

The case is stated in the opinion.