Stevens v. Commissioner

**Stevens v. Commissioner: Tax Exemption for Native American Income** This 1969 case involved a member of the Gros Ventre Tribe who farmed and ranched on over 20,000 acres at the Fort Belknap Indian Reservation in Montana during 1958-1959. Stevens had acquired this land through various means: some through government allotment, some as a gift from his mother (who had also received it by allotment), some through leases and permits, some by purchase, and some through inheritance transfers handled by the Indian Bureau. The dispute centered on whether Stevens had to pay federal income tax on money he earned from farming and ranching these different parcels of land. The IRS argued he owed taxes on all his farming income, while Stevens claimed it should be exempt under laws protecting Native American trust land income. The court issued a mixed ruling. Stevens won partial exemption for income earned on land he received through allotment, gifts from family members who had allotted land, and inherited land transferred through official Indian Bureau processes. However, he still had to pay taxes on income from land he leased, purchased, or obtained through permits. **Why this matters for workers:** This ruling clarifies that Native American workers can claim tax exemptions on income from certain types of trust lands, but the exemption depends on how they acquired the land, not just their tribal membership.