Brushaber v. Union Pacific Railroad Co.
E349807
Brushaber v. Union Pacific Railroad Co. is a 1916 U.S. Supreme Court case that upheld the federal income tax and clarified the scope and constitutionality of the Sixteenth Amendment.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Brushaber v. Union Pacific Railroad Co. canonical | 2 |
| Frank R. Brushaber v. Union Pacific Railroad Company | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T3340812 — 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: Brushaber v. Union Pacific Railroad Co. Context triple: [Sixteenth Amendment to the United States Constitution, relatedCourtCase, Brushaber v. Union Pacific Railroad Co.]
-
A.
Chicago, Burlington & Quincy Railroad Co. v. Chicago
Chicago, Burlington & Quincy Railroad Co. v. Chicago is an 1897 U.S. Supreme Court case that marked a key step in applying federal constitutional protections—particularly just compensation for takings—to the states through the Fourteenth Amendment.
-
B.
Palsgraf v. Long Island Railroad Co.
Palsgraf v. Long Island Railroad Co. is a landmark 1928 New York Court of Appeals case, authored by Judge Benjamin Cardozo, that established the modern American doctrine of proximate cause and foreseeability in negligence law.
-
C.
United States v. Darby
United States v. Darby is a 1941 U.S. Supreme Court case that upheld federal labor regulations under the Commerce Clause and marked a broad expansion of federal power over economic activity.
-
D.
West Coast Hotel Co. v. Parrish
West Coast Hotel Co. v. Parrish is a 1937 U.S. Supreme Court decision that upheld minimum wage laws and effectively ended the Lochner era by allowing greater government regulation of economic conditions.
-
E.
California Motor Transport Co. v. Trucking Unlimited
California Motor Transport Co. v. Trucking Unlimited is a 1972 U.S. Supreme Court case that addressed the limits of First Amendment petitioning rights when parties allegedly use governmental and judicial processes as part of an anticompetitive scheme in violation of antitrust laws.
- 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: Brushaber v. Union Pacific Railroad Co. Target entity description: Brushaber v. Union Pacific Railroad Co. is a 1916 U.S. Supreme Court case that upheld the federal income tax and clarified the scope and constitutionality of the Sixteenth Amendment.
-
A.
Chicago, Burlington & Quincy Railroad Co. v. Chicago
Chicago, Burlington & Quincy Railroad Co. v. Chicago is an 1897 U.S. Supreme Court case that marked a key step in applying federal constitutional protections—particularly just compensation for takings—to the states through the Fourteenth Amendment.
-
B.
Palsgraf v. Long Island Railroad Co.
Palsgraf v. Long Island Railroad Co. is a landmark 1928 New York Court of Appeals case, authored by Judge Benjamin Cardozo, that established the modern American doctrine of proximate cause and foreseeability in negligence law.
-
C.
United States v. Darby
United States v. Darby is a 1941 U.S. Supreme Court case that upheld federal labor regulations under the Commerce Clause and marked a broad expansion of federal power over economic activity.
-
D.
West Coast Hotel Co. v. Parrish
West Coast Hotel Co. v. Parrish is a 1937 U.S. Supreme Court decision that upheld minimum wage laws and effectively ended the Lochner era by allowing greater government regulation of economic conditions.
-
E.
California Motor Transport Co. v. Trucking Unlimited
California Motor Transport Co. v. Trucking Unlimited is a 1972 U.S. Supreme Court case that addressed the limits of First Amendment petitioning rights when parties allegedly use governmental and judicial processes as part of an anticompetitive scheme in violation of antitrust laws.
- F. None of above. chosen
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
federal income tax case ⓘ |
| areaOfLaw | federal constitutional tax law ⓘ |
| citation |
240 U.S. 1
ⓘ
36 S. Ct. 236 ⓘ 60 L. Ed. 493 ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1916-01-24 ⓘ |
| defendant |
Union Pacific Railroad
ⓘ
surface form:
Union Pacific Railroad Company
|
| dissentingJustices | none ⓘ |
| distinguishedFrom |
Pollock v. Farmers' Loan & Trust Co.
ⓘ
surface form:
Pollock v. Farmers’ Loan & Trust Co.
|
| fullName |
Brushaber v. Union Pacific Railroad Co.
self-linksurface differs
ⓘ
surface form:
Frank R. Brushaber v. Union Pacific Railroad Company
|
| holding |
The Supreme Court held that the Sixteenth Amendment authorizes a non-apportioned direct income tax.
ⓘ
Sixteenth Amendment to the United States Constitution ⓘ
surface form:
The Supreme Court held that the Sixteenth Amendment removed the requirement of apportionment for taxes on incomes from whatever source derived.
The Supreme Court held that the income tax under the Sixteenth Amendment is not required to be apportioned among the states according to population. ⓘ United States taxation and revenue case law ⓘ
surface form:
The Supreme Court rejected the argument that the income tax violated the Fifth Amendment Due Process Clause.
United States taxation and revenue case law ⓘ
surface form:
The Supreme Court rejected the argument that the income tax was a taking of property without due process of law.
Revenue Act of 1913 ⓘ
surface form:
The Supreme Court upheld the constitutionality of the federal income tax imposed by the Revenue Act of 1913.
|
| issue |
whether the Sixteenth Amendment changed the classification of income taxes as direct or indirect taxes
ⓘ
whether the federal income tax under the Revenue Act of 1913 violated constitutional requirements of apportionment ⓘ whether the income tax violated the Fifth Amendment Due Process Clause ⓘ |
| jurisdiction | federal ⓘ |
| languageOfProceedings | English ⓘ |
| legalEffect |
clarified the scope of the Sixteenth Amendment
ⓘ
confirmed the federal government’s power to levy an income tax without apportionment among the states ⓘ limited challenges to the federal income tax based on direct tax and apportionment arguments ⓘ |
| legalSubject |
Sixteenth Amendment to the United States Constitution
ⓘ
federal income tax ⓘ taxing and spending power of the United States ⓘ |
| majorityOpinionBy | Charles Evans Hughes ⓘ |
| partyType | individual taxpayer vs. corporation ⓘ |
| plaintiff | Frank R. Brushaber ⓘ |
| precededBy |
Pollock v. Farmers' Loan & Trust Co.
ⓘ
surface form:
Pollock v. Farmers’ Loan & Trust Co.
|
| recognizedPrinciple |
Congress may tax incomes from property without apportionment under the Sixteenth Amendment
ⓘ
the Sixteenth Amendment did not confer a new power of taxation but removed the apportionment requirement for income taxes ⓘ |
| relatedConstitutionalProvision |
Article I, Section 2 of the United States Constitution
ⓘ
Article I, Section 9 of the United States Constitution ⓘ Fifth Amendment to the United States Constitution ⓘ Sixteenth Amendment to the United States Constitution ⓘ |
| relatedLegislation | Revenue Act of 1913 ⓘ |
| result | judgment for Union Pacific Railroad Company ⓘ |
| subsequentCitation | cited as precedent in later income tax and Sixteenth Amendment cases ⓘ |
| topic |
United States constitutional law
ⓘ
tax law ⓘ |
| vote | 8–0 ⓘ |
| yearDecided | 1916 ⓘ |
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: Brushaber v. Union Pacific Railroad Co. Description of subject: Brushaber v. Union Pacific Railroad Co. is a 1916 U.S. Supreme Court case that upheld the federal income tax and clarified the scope and constitutionality of the Sixteenth Amendment.
Referenced by (3)
Full triples — surface form annotated when it differs from this entity's canonical label.
Sixteenth Amendment to the United States Constitution
→
relatedCourtCase
→
Brushaber v. Union Pacific Railroad Co.
ⓘ
Direct Tax Clause of the United States Constitution
→
interpretedInCase
→
Brushaber v. Union Pacific Railroad Co.
ⓘ
Brushaber v. Union Pacific Railroad Co.
→
fullName
→
Brushaber v. Union Pacific Railroad Co.
self-linksurface differs
ⓘ
this entity surface form:
Frank R. Brushaber v. Union Pacific Railroad Company