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United States v. Kaiser

363 U.S. 299 (1960)

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United States v. Kaiser

United States Supreme Court
363 U.S. 299 (1960)

JR

Facts

In 1954, Kaiser (plaintiff) participated in a union labor strike. The organizing union provided strikers with strike assistance such as room rent and food vouchers. Kaiser received both room rent and food vouchers from the union despite not being a member. On his federal income-tax return, Kaiser did not include the strike assistance in his gross income. The Internal Revenue Service (defendant) informed Kaiser that the strike assistance should have been included in his gross income and required him to make an additional payment. Kaiser first sought an administrative refund of the additional payment, which was rejected. Kaiser then sued for a refund in district court. In the district court, the jury found that the strike assistance was a gift and not taxable income to Kaiser. The jury evaluated several factors in determining whether the strike assistance was a gift, such as the type of assistance given, the amount of assistance, the need for the assistance, the lack of other income or public assistance, and whether Kaiser had dependents. After several appeals, the United States Supreme Court was petitioned for review.

Rule of Law

Issue

Holding and Reasoning (Brennan, J.)

Concurrence (Frankfurter, J.)

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Federal Income Tax

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