Nix v. Hedden one of the first companies to ship produce from Virginia, Florida, and Bermuda to New York. In 1883, President Chester A. Arthur signed the Tariff Act of March 3, 1883, requiring a tax to be paid on imported vegetables, but not fruit. The John Nix & Co. company filed a suit against Edward L. Hedden, Collector of the Port of New York, to recover back duties paid under protest. They argued against the tariff by pointing out that, botanically, a tomato is a fruit due to its seed-bearing structure growing from the flowering part of a plant. At the trial,
Realization (tax) Realization (tax) Realization, for U.S. Federal income tax purposes, is a requirement in determining what must be included as income subject to taxation. It should not be confused with the separate concept of Recognition (tax). Realization is a trigger for calculating income taxation. It is one of the three principles for defining income under the seminal case in this area of tax law, "Commissioner v. Glenshaw Glass Co." In that case, the Supreme Court determined that income generally means "undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion." It is also discussed in "Helvering v.