Nix v. Hedden Nix v. Hedden Nix v. Hedden, 149 U.S. 304 (1893), was a decision by the Supreme Court of the United States that, under U.S. customs regulations, the tomato should be classified as a vegetable rather than a fruit. The Court's unanimous opinion held that the Tariff Act of 1883 used the ordinary meaning of the words "fruit" and "vegetable," instead of the technical botanical meaning. John Nix founded the John Nix & Co. fruit commission in New York City in 1839. The company became one of the largest sellers of produce in New York City at the time, and was
Commissioner v. Duberstein for taxation purposes was the same as "gift" in common law terms. "Duberstein" at 285. The Court also rejected the premise that there is a bright line as to what constitutes a gift for taxation purposes. "Id" at 287. Instead, when determining whether something is a gift for taxation purposes, the critical consideration is the transferor's intention. "Duberstein" at 285-286 (citing "Bogardus v. Commissioner", ). This is a question of fact that must be determined on a "case-by-case basis". "Duberstein" at 290. The body that levies the tax must conduct an objective inquiry that looks to "the mainsprings of human