United States v. Basye et al.

Decided February 27, 1973. Lewis Franklin Powell Jr. delivered the opinion of the Court.

Docket 71-1022 · 410 U.S. 441 (1973) · Cited 356 times

Holding

The retirement fund payments notwithstanding the fact that they were contributed directly to the trust, were compensation for services that Permanente rendered under the medical-service agreement and should have been reported as income to Permanente; and the individual partners should have included their shares of that income in their individual returns, since the existence of conditions upon the actual receipt by a partner of income fully earned by the partnership is not a relevant factor in determining its taxability to him.

The Court’s statement of the holding, from the opinion’s syllabus. The syllabus is prepared by the Reporter of Decisions and is not part of the opinion of the Court — read the official opinion for authority.

How the Justices voted

Decided 8–1.

“Concurring” means agreeing with the outcome; any split shown is the Court’s judgment, not each Justice’s reasoning. Source: the Supreme Court Database (Spaeth et al.), Washington University.

Precedents cited

Supreme Court decisions this opinion relies on, ordered by how often it cites each. Cases in our collection link through; others are named.

• Lucas v. Earl · 281 U.S. 111 (1930)
• Heiner v. Mellon · 304 U.S. 271 (1938)
• Commissioner v. Culbertson · 337 U.S. 733 (1949)
• Bingler v. Johnson · 394 U.S. 741 (1969)
• Commissioner v. LoBue · 351 U.S. 243 (1956)
• Helvering v. Eubank · 311 U.S. 122 (1941)
• Burnet v. Leininger · 285 U.S. 136 (1932)
• United States v. Joliet & Chicago Railroad · 315 U.S. 44 (1942)
• Commissioner v. First Security Bank of Utah, N. A. · 405 U.S. 394 (1972)

Cited by

Later Supreme Court opinions in our collection that cite this case.

• Moore v. United States · 602 U.S. 572 (2024)
• Bellis v. United States · 417 U.S. 85 (1974)
• Commissioner v. Banks · 543 U.S. 426 (2005)

Official text

Read the official opinion (U.S. Reports, govinfo.gov)

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Lewis Franklin Powell Jr.’s profile · All Supreme Court opinions · The Supreme Court

Source: Supreme Court of the United States, slip opinions (1973). Citation count from the Free Law Project’s CourtListener bulk data. Data last verified 2026-07-03. Informational only; verify against the primary source before relying. Not a consumer report (FCRA).