Hillsboro National Bank v. Commissioner
United States Supreme Court
460 U.S. 370 (1983)
Hillsboro National Bank (bank) (plaintiff) was incorporated in Illinois. Hillsboro’s shareholders were subject to a state property tax on their shares. Hillsboro paid the property tax on behalf of its shareholders, and then deducted the payments from its federal income taxes. In 1970, the state repealed the property-tax law, but the repeal did not take effect until 1973. From 1970 to 1973, the state continued to enforce the property tax and escrow property-tax collections. When the repeal finally took effect, the state refunded the escrowed property taxes directly to Hillsboro’s shareholders, not to Hillsboro itself. Hillsboro reasoned that it had recovered none of its 1970-1973 tax payments, and therefore did not need to report the tax refunds as income. The commissioner of internal revenue (commissioner) (defendant) determined that the refunds should have been included in Hillsboro’s tax return. Hillsboro petitioned the tax court for a redetermination. The tax court ruled for the commissioner, and the United States Court of Appeals for the Seventh Circuit affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (O’Connor, J.)
What to do next…
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 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
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. Read more about Quimbee.
Here's why 177,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 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.