In Killian v. United States, a labor union officer was convicted under 18 U.S.C. § 1001 for falsely stating in a required NLRA § 9(h) affidavit that he was not a member of or affiliated with the Communist Party, allowing his union to access NLRB processes. The Supreme Court granted certiorari on whether the Jencks Act (18 U.S.C. § 3500) required production of government informants' expense statements and receipts when the government offered a list of payment dates and amounts, and whether the jury instructions adequately defined membership and affiliation. The Court held that the government's limited disclosure satisfied the statute and that the instructions properly defined the terms by reference to the defendant's subjective belief and objective acts showing commitment to the Party. The reasoning centered on statutory interpretation of production obligations tied to direct testimony and on the established legal meaning of Party membership as a secret, disciplined relationship rather than mere sympathy or isolated cooperation.
This case concerned the tax treatment of a transaction where a taxpayer exchanged all stock in his corporation for stock in another company plus a large cash payment. The Supreme Court held that the entire gain from the exchange must be recognized for income tax purposes, rather than only to the extent of the cash received. The Court reasoned that the nonrecognition provisions of the Internal Revenue Code apply only in the context of a qualifying corporate reorganization, which requires an exchange solely for voting stock, and the statutory provisions for partial recognition do not create a hypothetical reorganization when cash is also received.
The case involved three defendants convicted after nolo contendere pleas to charges of willfully attempting to evade federal income taxes; after the district court pronounced sentence in June 1959, they filed motions in arrest of judgment within ten days and appealed within ten days after those motions were denied. The Fifth Circuit dismissed the appeals as untimely under the Federal Rules of Criminal Procedure, reasoning that Rule 34's five-day limit on such motions after determination of guilt modified the appeal deadline in Rule 37(a)(2). The Supreme Court reversed, holding the appeals timely because Rule 37(a)(2) expressly permits an appeal within ten days after entry of the order denying a motion in arrest of judgment that was made within the ten-day period following entry of the judgment, without incorporating Rule 34's timing requirement. The Court relied on the plain language of Rule 37(a)(2), its caption as the sole rule addressing the time for appeal, and the need to avoid creating procedural traps that could forfeit the right to appeal.
This case concerned whether Grant County, Washington, could validly assess and collect property taxes on Wherry Act leaseholds held by private corporations on a federal military base, after the county valued those leaseholds at the full value of the buildings and improvements—higher than the valuation method used for comparable non-federal leaseholds. The Supreme Court held that the taxes were invalid because they discriminated against the United States and its lessees in violation of the Constitution and § 511 of the Housing Act of 1956. The Court reasoned that a state may not impose taxes on federal leasehold interests that exceed the amount levied on similar property of similar value, and that the prior state-court decision did not bar the discrimination claim because no taxes had yet been assessed at that time. It therefore reversed the Ninth Circuit's judgment sustaining the taxes and directed that the county's claims be disallowed.
The case concerned whether home buyers could recover damages from the United States under the Federal Tort Claims Act after relying on an FHA appraisal that failed to detect structural defects in a house, leading them to pay more than the property's fair market value. The Supreme Court held that the claim was barred by the FTCA's exception in 28 U.S.C. § 2680(h) for claims arising out of misrepresentation. The Court reasoned that the buyers' action, though framed as negligence in the inspection, fundamentally depended on the government's communication of an inaccurate property value, which fell within the statutory exclusion; it noted that FHA appraisals were intended to protect the government rather than to create duties to purchasers. The decision emphasized congressional intent to preclude liability for such statements and distinguished the claim from other forms of negligence not centered on misrepresentation.
This case involved a dispute between the United States and Consolidated Edison over the proper tax year for deducting contested real estate taxes paid under protest by the accrual-basis taxpayer. The taxpayer had paid the full assessed taxes to avoid penalties and property seizure while contesting valuations, then sought to deduct the contested portions in the year of payment, with adjustments in the year of resolution. The Supreme Court held that the contested taxes accrued only in the year the contest was finally determined, not the year of payment. The core reasoning relied on the "all events" test, which requires that all events fixing the fact and amount of liability must occur before accrual, and a contested liability does not meet this until resolved.
