The IRS’s Hollow Victory in Crane v. Commissioner, 331 U.S. 1 (1947)
[Editors’ note: This is the fourth in our series, What Is the Most Important U.S. Supreme Court Case in Your Area of the Law? The first three installments are here, here, and here.]
There are many important Supreme Court tax cases. However, few are identifiable just by reference to a footnote number. Tax scholars and academics will easily recognize the Supreme Court’s decision in Crane v. Commissioner simply by reference to footnote 37. In my opinion, Crane is the most important case in tax history, and footnote 37 is the most famous footnote.
The issues presented in Crane arose when the taxpayer inherited an apartment building from her husband.