Supreme Court of the United States
Squire v. Capoeman
April 23, 1956351 U.S. 1
Summary
The Court affirmed the Ninth Circuit, holding that the proceeds from the sale of timber on the Capoeman's allotted Indian land were exempt from federal capital‑gains tax because the General Allotment Act’s Section 6 amendment and the treaty language prohibiting "charge or incumbrance" preclude taxation until a fee‑simple patent is issued. The decision emphasizes interpreting ambiguous treaty provisions in favor of Indian wards.
Holding
- Whether the proceeds from the sale of timber on Indian trust‑allotted land are subject to federal capital‑gains tax consistent with the Quinaielt treaty, the General Allotment Act, and the United States’ guardian‑ward relationship with the Indians. The proceeds are exempt from federal income tax because the treaty’s prohibition of "charge or incumbrance" and the Section 6 amendment to the General Allotment Act forbid taxation of income derived from restricted allotments until a fee‑simple patent is issued.
Docket 134
Cited authorities
- T. D. 3570
- T. D. 3754
- 12 Stat. 971
- 24 Stat. 388
- 25 U.S.C. § 331
- 25 U.S.C. § 331
- 25 U.S.C. § 348
- 25 U.S.C. § 462
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- Estate of Robert Poletti, LaBarbara T. Poletti, Personal Representative & LaBarbara T. Poletti v. Commissioner of…
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