Moore v. United States
U.S. Supreme Court · decided June 20, 2024 · Supreme Court Database (Spaeth)
- Decided
- June 20, 2024
- Term
- October Term 2023
- Vote
- 7–2
- Majority author
- Justice Kavanaugh
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
PRELIMINARY PRINT Volume 602 U. S. Part 1 Pages 572–652 OFFICIAL REPORTS OF THE SUPREME COURT June 20, 2024 Page Proof Pending Publication REBECCA A. WOMELDORF reporter of decisions NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. Syllabus MOORE et ux. v. UNITED STATES certiorari to the united states court of appeals for the ninth circuit No. 22–800. Argued December 5, 2023—Decided June 20, 2024 Congress generally taxes the income of American business entities in one of two ways. Some entities, such as S corporations and partnerships, are taxed on a pass-through basis, where the entity itself does not pay taxes. 26 U. S. C. §§ 1361–1362. Instead, the entity's income is attrib- uted to the shareholders or partners, who then pay taxes on that income even if the entity has not distributed any money or property to them. §§ 61(a)(12), 701, 1366(a)–(c). Other business entities do pay taxes di- rectly on their income. Those entities' shareholders ordinarily are not taxed on that income but are taxed when the entity distributes a divi- dend or when the shareholder sells shares. Congress treats American-controlled foreign corporations as pass- through…
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