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Rudolph v. United States

United States Supreme Court
370 U.S. 269 (1962)


Facts

As a top-selling insurance agent, C.J.D. Rudolph (plaintiff) was rewarded by his employer with an all-expenses-paid trip to New York. The trip consisted of a half-day convention, followed by two days of sightseeing and entertainment with other top-selling agents and their wives. The New York trip primarily was a “pleasure trip” intended to reward top-selling agents for their performance. The federal tax commissioner (commissioner) determined a deficiency in Rudolph’s taxes, finding that Rudolph had failed to include the value of the New York trip in his gross income. Rudolph paid the deficiency and then filed suit against the United States government (government) (defendant) in federal district court, seeking a refund. The district court entered judgment for the government. The court of appeals affirmed, and the United States Supreme Court granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Per curiam)

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Concurrence (Harlan, J.)

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Dissent (Harlan, J.)

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