22a USC 1939 – Embezzled funds

Embezzled money is taxable income of the embezzler in the year of the embezzlement under 22 (a) of the Internal Revenue Code of 1939, which defines “gross income” as including “gains or profits and income derived from any source whatever,” and under 61 (a) of the Internal Revenue Code of 1954, which defines “gross income” as “all income from whatever source derived.” Commissioner v. Wilcox, 327 U.S. 404 , overruled. Pp. 213-222.