In Greene v. United States, taxpayers who sold land to a utility company threatening condemnation reported only part of the contract price as taxable gain on their joint return, attributing the rest to severance damages to their retained adjoining property; the IRS treated the full price as payment for the land sold and assessed a deficiency. The taxpayers paid the tax and sued for a refund, arguing that preliminary negotiations showed the parties' true intent and that substance should control over the contract's form. The court granted the government's motion to dismiss, holding that the unambiguous written contract price governs tax consequences and cannot be contradicted by prior negotiations in the absence of fraud.
The case involved a film distributor challenging Chicago's municipal code requiring permits for motion pictures, under which the city had restricted exhibition of the film 'Desire Under the Elms' to adults over age 21 on grounds that it tended to create a harmful impression on children. The plaintiff sought to enjoin enforcement of the restrictions, arguing that the relevant code sections (155-4 and 155-5) constituted an unconstitutional prior restraint on freedom of expression under the First and Fourteenth Amendments. The court determined that the ordinance was unconstitutionally vague, as concepts like 'immoral or obscene' are absolute rather than age-dependent, and phrases such as 'tends toward creating a harmful impression on the minds of children' provide no clear or rational guide for censors. Reading the sections together revealed an inherent contradiction in applying the same standards differently to adults and minors, rendering the limited-permit mechanism invalid under precedents requiring precise language in censorship statutes.
This case involved a Canadian corporation filing an admiralty action against the City of Chicago to recover for damage to its ship allegedly caused by the city's negligent operation of a drawbridge over the Chicago River. The city moved to dismiss, arguing both that the suit was effectively against the State of Illinois and thus barred by the Eleventh Amendment, and that bridge operation was a governmental function for which the city enjoyed immunity from tort liability. The court denied the motion, holding that municipalities like Chicago are separate entities from the state with their own taxing and operational powers, so the Eleventh Amendment does not apply, and that under Illinois precedent the operation of the bridge was a corporate rather than governmental function subject to negligence claims.
This case concerned IRS efforts to enforce subpoenas requiring taxpayers to produce books and records for reexamination, including situations where the statute of limitations might bar assessment unless fraud was involved. The court held that the Commissioner’s written notice of reexamination under 26 U.S.C. § 7605(b) is insufficient by itself and that a judicial hearing is required so the government can demonstrate the relevance and necessity of the examination. It further ruled that when the tax years are time-barred, an affidavit alleging unconfirmed information from another agency does not establish reasonable grounds to suspect fraud, again necessitating a hearing under 26 U.S.C. § 7604(b) at which the government must make an adequate showing before enforcement. The core reasoning was that the relevant Internal Revenue Code provisions limit the Secretary’s discretion and expressly require court review to ensure compliance with statutory standards of materiality, necessity, and reasonable suspicion of fraud.
This case involves a seaman's complaint against his employer under the Merchant Marine Act of 1920 (Jones Act) for damages from injuries sustained while working on a boat in navigable waters bordering Illinois. The defendant, a Delaware corporation, moved to quash service of process made under the Illinois Non-Resident Water Craft Act, arguing the statute was unconstitutional, and raised other objections including the need to elect between Jones Act and unseaworthiness claims and lack of jurisdiction under the Act's venue provisions. The court overruled the motion to quash, finding the service statute constitutional by analogy to upheld nonresident motorist provisions and the state's equal power over navigable waters and highways. It also rejected the election requirement as unnecessary and found the jurisdiction objection unsupported on the current record, as residence can include doing business in the state. The court therefore denied the defendant's motions to quash service and to strike counts for failure to elect.
The case involved a defendant indicted under 18 U.S.C. § 871 for allegedly threatening the life of the President of the United States by posting statements such as “There can be slain no sacrifice to God more acceptable than an unjust President” and remarks about officials being arrested and shot. After a psychiatric examination was ordered under 18 U.S.C. § 4244 to assess the defendant's competency to stand trial, the court examined whether the indictment charged a federal offense at all. The court held that the statements did not constitute a threat because they lacked any expression of intent to injure the current President and could refer to past or future leaders. As a result, the indictment was dismissed for failure to state an offense against the United States, which eliminated the court's authority to proceed with the competency hearing under § 4244.
