Supreme Court of the United States
Squire v. Capoeman
April 23, 1956351 U.S. 1
Summary
The Court affirmed the Court of Appeals, holding that the capital‑gain tax imposed on the sale of standing timber from the respondents' allotted Indian land held in trust was invalid because the treaty, the General Allotment Act, and the trust patent exempted such income until a fee patent was issued. The decision relied on a construction of treaty language in favor of the Indians and on congressional intent expressed in the Allotment Act. Justice Reed dissented, arguing the timber sale produced a taxable capital gain.
Holding
- Whether the proceeds from the sale of timber on Indian allotment land held in trust are subject to federal income tax under the Internal Revenue Code, given the treaty, the General Allotment Act, and the trust patent.. The tax is invalid; the respondents are not liable for income tax on the timber sale because the treaty and Section 6 of the General Allotment Act exempt income derived from restricted allotments until a fee 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