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

U.S. Supreme Court

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

Robertson v. United States

No. 388

Argued March 31, 1952

Decided June 2, 1952

343 U.S. 711

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. 343 U. S. 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. 343 U. S. 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. 343 U. S. 716.