Biddle v. Commissioner of Internal Revenue

302 U.S. 573, 58 S. Ct. 379, 82 L. Ed. 431 (1938)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

Biddle v. Commissioner of Internal Revenue

United States Supreme Court
302 U.S. 573, 58 S. Ct. 379, 82 L. Ed. 431 (1938)

Facts

Biddle (plaintiff) was an American taxpayer who received cash dividends from stock in British corporations. This suit was a consolidation of multiple similar cases. British corporations paid the taxes on such dividends at the point of profits, meaning the British corporation itself either paid or at least was responsible for paying the normal rate taxes. A surtax was then charged to individuals whose income exceeded a certain amount. In such cases, the British entity then sent a statement indicating the gross amount from which the taxes appropriate were deducted, the rate and amount of income tax appropriate to that gross amount, and the net amount paid. The British corporations had the right to either subtract the tax before distribution or declare a dividend free of tax, in which case the taxpayer was shown the tax appropriate for the dividend and paid that remaining amount. The mechanics of this were to allow taxpayers not subject to the surtax to claim a rebate. Biddle included the sums reported in the British returns in his gross income. Biddle then claimed as credit the amount of British tax appropriate to the dividends and the amount of surtax paid. The Commissioner of Internal Revenue (the commissioner) (defendant) assessed a deficiency against this practice. The commissioner argued that the tax appropriate was not actually the amount of income taxes paid by the taxpayer but rather by the corporation and thus must not be credited as taxes paid. Biddle argued that the nature of British taxation essentially meant that he should be allowed to credit the tax appropriate to the dividend, or if not, Biddle must at least be able to offset his gross income by this amount.

Rule of Law

Issue

Holding and Reasoning (Stone, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 734,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 734,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 734,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership