North American Oil Consolidated v. Burnet

While the government's suit to oust North American Oil (plaintiff) from disputed oil land was pending, a receiver managed the property and held its net profits; after the company won the suit in 1917, the receiver paid it the 1916 net profits. The company initially did not report the 1916 profits as 1917 income, but the Commissioner (defendant) argued the payment was taxable to the company in 1917, while the Board of Tax Appeals had found it taxable to the receiver instead; the Ninth Circuit sided with the Commissioner, and the company sought Supreme Court review.