Patricia Polanco v. Ralph Diaz

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that taxable income is not a growth of an investment, but is “a gain, a profit, something of exchangeable value”
• noting that the phrase “any court ... includes both state and federal courts.”
• describing Article I, section 9, clause 4, as a “limitation upon the taxing power of Congress” that is “not to be overridden by Congress or disregarded by the courts”
• using the analogy of a tree and its fruit to illustrate the important distinction between a transfer involving capital, that is, an asset that produces a benefit, and one involving income, or the benefit itself
• for tax purposes, income is not the growth in the value of an investment, but rather the gain realized from the disposition of that investment
• for tax purposes, income is not the growth in the value of an investment, but rather the gain realized from the disposition of that investment

Source: CourtListener parenthetical corpus (CC0).