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United States v. Schurz

• 1880 • 102 U.S. 378 • Waite Court
United States v. Schurz was a United States Supreme Court case that dealt with the issue of whether the United States government had the right to tax a foreign corporation operating in the United States. The case involved a German corporation, Schurz & Co., which had been operating in the United States since 1867. The United States government had imposed a tax on the company's income, which the company refused to pay. The company argued that it was not subject to the tax because it was a...Open Case
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Chief Waite Court
Term: 1880
Docket: 707
102 U.S. 378
26 L. Ed. 167
1880 U.S. LEXIS 2047
Argued: Nov 09, 1880

United States v. Schurz

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Opinion Summary
AI Abstract

United States v. Schurz was a United States Supreme Court case that dealt with the issue of whether the United States government had the right to tax a foreign corporation operating in the United States. The case involved a German corporation, Schurz & Co., which had been operating in the United States since 1867. The United States government had imposed a tax on the company's income, which the company refused to pay. The company argued that it was not subject to the tax because it was a foreign corporation and not subject to the jurisdiction of the United States. The Supreme Court held that the United States government had the right to tax the company's income. The Court reasoned that the company was subject to the jurisdiction of the United States because it was doing business in the United States and was thus subject to the laws of the United States. The Court also held that the tax was not an unconstitutional burden on the company because it was a reasonable exercise of the government's power to tax. In conclusion, the Supreme Court held that the United States government had the right to tax the income of a foreign corporation operating in the United States. The Court reasoned that the company was subject to the jurisdiction of the United States and that the tax was a reasonable exercise of the government's power to tax.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in United States v. Schurz, arguing that the majority's decision was contrary to both precedent and statute. He argued that under prior decisions of this Court, a contract between two parties could not be voided by one party simply because it had been entered into without consideration or with inadequate consideration; rather, such contracts were valid until they were set aside for fraud or mistake. Furthermore, he noted that Congress had passed a law specifically allowing Indian tribes to enter into agreements with non-Indians concerning land transactions without any requirement of consideration being exchanged. Thus, Justice Field concluded that since no fraud or mistake was alleged in this case and since Congress had authorized such agreements without requiring any exchange of value from either side, the agreement at issue should have been enforced as written by the lower court and not overturned on appeal by this Court.

Opinion written by Justice SFMiller
Decided: Dec 13, 1880
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