James v. United States Case Brief Summary | Law Case Explained

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James v. United States | 366 U.S. 213 (1961)

In Commissioner versus Wilcox, the United States Supreme Court held that embezzled funds weren’t taxable and shouldn’t be included in a taxpayer’s gross income. That decision appeared inconsistent with decisions that other forms of illegally acquired income were taxable. Fifteen years after Wilcox, in James versus United States, the Supreme Court reevaluated the taxability of embezzled funds as it sought to reconcile its ostensibly conflicting positions.

Between 1951 and 1954, James embezzled over seven hundred thousand dollars. He declined to include the embezzled funds in his gross income on his relevant federal tax returns. As a result, James was charged with willfully attempting to evade federal income tax.

The district court convicted James. The Seventh Circuit affirmed, and the United States Supreme Court granted cert.

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