Tags
Glenshaw-Glass
Doctrine
Unresolved
What "Income" Means — and Why a Century of Case Law Hasn't Settled It
The Sixteenth Amendment uses 'income' without defining it. Eisner v. Macomber tried. Commissioner v. Glenshaw Glass tried again. Neither fully succeeded. The resulting ambiguity is not a conspiracy — it's a real doctrinal gap with real consequences.
Questions
Unresolved
Whether Glenshaw Glass expanded "income" beyond the original constitutional meaning
A live academic question: did the 1955 Glenshaw Glass formulation broaden 'income' past what the Sixteenth Amendment originally authorized?