not to be confused with United States v. Robertson, 514 U.S. 669 (1995)

Robertson v. United States, , was an income tax case before the U.S. Supreme Court discussing, under United States tax law, whether prizes are exempt as gifts under §102(a).

The facts of the case involve American composer Leroy Robertson

Leroy Robertson

Leroy Robertson was an American composer and music educator.Robertson was born in Fountain Green, Utah. One of his earliest instructors was Anthony C. Lund. He studied violin, composition, and public school music at the New England Conservatory and in Europe...

entering a previously composed symphony, Trilogy, into a 1947 contest for musical compositions. Robertson won $25,000, claimed the prize on his income taxes as income attributable to the three years he wrote it (1937 through 1939), and thereafter claimed a refund that treated his winnings as a gift.

The case is notable, and thus appears in law school casebooks, for the following holdings:

• A cash prize received by the winner of a contest in musical composition is "gross income" within the meaning of § 22(a) of the Internal Revenue Code, and it is not a "gift" excluded from gross income by § 22(b)(3). Pp. 343 U. S. 713-714.

• In computing under § 107(b), the tax on such a cash prize for a musical composition, the income should be attributed to the 36 months ending with the close of the year in which it was received -- not some earlier period of 36 months during which the taxpayer worked on the composition. Pp. 343 U. S. 714-716.