United States v. Lewis (340 U.S. 590)
U.S. Supreme Court · decided March 26, 1951 · Supreme Court Database (Spaeth)
- Citation
- 340 U.S. 590 · 71 S. Ct. 522
- Decided
- March 26, 1951
- Term
- October Term 1950
- Vote
- 8–1
- Majority author
- Justice Black
- Issue area
- Federal Taxation
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Mr. Justice Black delivered the opinion of the Court. Respondent Lewis brought this action in the Court of Claims seeking a refund of an alleged overpayment of his 1944 income tax. The facts found by the Court of Claims are: In his 1944 income tax return, respondent reported about $22,000 which he had received that year as an employee’s bonus. As a result of subsequent litigation in a state court, however, it was decided that respondent’s bonus had been improperly computed; under compulsion of the state court’s judgment he returned approximately $11,000 to his employer. Until payment of the judgment in 1946, respondent had at all times claimed and used the full $22,000 unconditionally as his own, in the good faith though “mistaken” belief that he was entitled to the whole bonus. On the foregoing facts the Government’s position is that respondent’s 1944 tax should not be recomputed, but that respondent should have deducted the $11,000 as a loss in his 1946 tax return. See G. C. M. 16730, XV-1 Cum. Bull. 179 (1936). The Court of Claims, however, relying on its own case, Greenwald v. United States, 102 Ct. Cl. 272, 57 F. Supp. 569, held that the excess bonus received “under a mistake of fact” was not income in 1944 and ordered a refund based on a recalculation of that year’s tax. 117 Ct. Cl. 336, 91 F. Supp. 1017. We granted cer-tiorari, 340 U. S. 903, because this holding…
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