Eisner v. Macomber
E296200
Eisner v. Macomber is a 1920 U.S. Supreme Court case that held a pro rata stock dividend was not taxable income under the Sixteenth Amendment, shaping early federal income tax doctrine.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Eisner v. Macomber canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T2748431 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Eisner v. Macomber Context triple: [Helvering v. Bruun, relatedCase, Eisner v. Macomber]
-
A.
Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
-
B.
United States v. Comstock
United States v. Comstock is a 2010 U.S. Supreme Court case that upheld Congress’s authority to civilly commit mentally ill, sexually dangerous federal prisoners beyond their release date under the Constitution’s Necessary and Proper Clause.
-
C.
Sherbert v. Verner
Sherbert v. Verner is a landmark 1963 U.S. Supreme Court case that strengthened protections for religious liberty by requiring strict scrutiny of government actions that substantially burden individuals’ religious practices.
-
D.
Nixon v. Fitzgerald
Nixon v. Fitzgerald is a 1982 U.S. Supreme Court case that established absolute immunity from civil damages liability for a President’s official acts.
-
E.
Rostker v. Goldberg
Rostker v. Goldberg is a 1981 U.S. Supreme Court case that upheld the constitutionality of requiring only men, and not women, to register for the military draft.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Eisner v. Macomber Target entity description: Eisner v. Macomber is a 1920 U.S. Supreme Court case that held a pro rata stock dividend was not taxable income under the Sixteenth Amendment, shaping early federal income tax doctrine.
-
A.
Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
-
B.
United States v. Comstock
United States v. Comstock is a 2010 U.S. Supreme Court case that upheld Congress’s authority to civilly commit mentally ill, sexually dangerous federal prisoners beyond their release date under the Constitution’s Necessary and Proper Clause.
-
C.
Sherbert v. Verner
Sherbert v. Verner is a landmark 1963 U.S. Supreme Court case that strengthened protections for religious liberty by requiring strict scrutiny of government actions that substantially burden individuals’ religious practices.
-
D.
Nixon v. Fitzgerald
Nixon v. Fitzgerald is a 1982 U.S. Supreme Court case that established absolute immunity from civil damages liability for a President’s official acts.
-
E.
Rostker v. Goldberg
Rostker v. Goldberg is a 1981 U.S. Supreme Court case that upheld the constitutionality of requiring only men, and not women, to register for the military draft.
- F. None of above. chosen
Statements (44)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
constitutional law case ⓘ tax law case ⓘ |
| appliesTo | pro rata stock dividends ⓘ |
| concernsAmendment | Sixteenth Amendment to the United States Constitution ⓘ |
| concernsAreaOfLaw |
constitutional limitations on taxation
ⓘ
federal income tax ⓘ |
| establishedDoctrine |
narrow definition of income for Sixteenth Amendment purposes
ⓘ
realization requirement for income taxation ⓘ |
| hasCitation | 252 U.S. 189 ⓘ |
| hasCountry | United States of America ⓘ |
| hasCourt | Supreme Court of the United States ⓘ |
| hasDecisionDate | 1920-03-08 ⓘ |
| hasDissentBy |
Justice James C. McReynolds
ⓘ
Justice John H. Clarke ⓘ Justice Louis D. Brandeis ⓘ Oliver Wendell Holmes Jr. ⓘ
surface form:
Justice Oliver Wendell Holmes Jr.
|
| hasHistoricalContext | post-ratification interpretation of the Sixteenth Amendment ⓘ |
| hasImpactOn |
Internal Revenue Code interpretation
ⓘ
constitutional constraints on federal tax policy ⓘ |
| hasJurisdiction | federal ⓘ |
| hasKeyConcept |
income
ⓘ
realization ⓘ stock dividend ⓘ |
| hasLanguage | English ⓘ |
| hasLegalSignificance |
limited congressional power to tax certain unrealized gains as income
ⓘ
shaped early federal income tax doctrine ⓘ |
| hasMajorityOpinionBy | Justice Mahlon Pitney ⓘ |
| hasPage | 189 ⓘ |
| hasPetitioner | Eisner ⓘ |
| hasReporter | United States Reports ⓘ |
| hasRespondent | Macomber ⓘ |
| hasSubsequentTreatment | narrowed by later Supreme Court income tax decisions ⓘ |
| hasVolume | 252 ⓘ |
| hasVote | 5–4 ⓘ |
| hasYear | 1920 ⓘ |
| holding |
A pro rata stock dividend is not taxable income under the Sixteenth Amendment
ⓘ
Stock dividends representing a capitalization of surplus are not realized income to shareholders ⓘ |
| interprets |
Sixteenth Amendment to the United States Constitution
ⓘ
surface form:
Sixteenth Amendment power to tax incomes without apportionment
|
| involvesIssue |
definition of income under the Sixteenth Amendment
ⓘ
realization of gain ⓘ taxability of stock dividends ⓘ |
| isTaughtIn |
United States constitutional law courses
ⓘ
United States federal income tax law courses ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Eisner v. Macomber Description of subject: Eisner v. Macomber is a 1920 U.S. Supreme Court case that held a pro rata stock dividend was not taxable income under the Sixteenth Amendment, shaping early federal income tax doctrine.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.