Rutkin v. United States (343 U.S. 130)
U.S. Supreme Court · decided March 24, 1952 · Supreme Court Database (Spaeth)
- Citation
- 343 U.S. 130 · 72 S. Ct. 571
- Decided
- March 24, 1952
- Term
- October Term 1951
- Vote
- 5–4
- Majority author
- Justice Burton
- Issue area
- Criminal Procedure
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Mr. Justice Burton delivered the opinion of the Court. The principal issue before us is whether money obtained by extortion is income taxable to the extortioner under § 22 (a) of the Internal Revenue Code. For the reasons hereafter stated we hold that it is. The petitioner, Rutkin, was indicted under 26 U. S. C. § 145 (b) for willfully attempting to evade and defeat a large part of his income and victory taxes for 1943. He was charged with filing a false and fraudulent return stating his net income to be $18,966.64, whereas he knew that it was $268,622.04. That difference, which would increase his tax liability from $6,843.93 to $222,408.32, was due largely to his omission from his original return of $250,000 received by him in cash from Joseph Reinfeld. The United States claims that this sum was obtained by petitioner by extortion and as such was taxable income. Petitioner contests both the fact that the money was obtained by extortion and the conclusion of law that it was taxable income if so obtained. He contends also that he did not willfully attempt to evade or defeat the tax. Petitioner was found guilty by a jury in the United States District Court for the District of New Jersey, fined $10,000 and sentenced to four years in prison. The Court of Appeals affirmed, one judge dissenting. 189 F. 2d 431. We granted certiorari, 342 U. S. 808, so as to pass upon the alleged…
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