Stratton's Independence, Ltd. v. Howbert, 231 U.S. 399 (1913), was a case before the U.S. Supreme Court that addressed the question of corporate taxation.

Stratton's Independence, Limited, a British corporation that owned and operated mines in Colorado, sued in a district court to recover taxes it had paid under protest in accordance with the provisions of the Corporation Tax Act of 1909.

The second question raised was whether or not proceeds from mining activities constituted "income" by the definition of the act.

Mining, Justice Pitney argued, is generally comparable to manufacturing, and is certainly a business; hence, the gains from this activity should be considered income for the purposes of taxation.

[1] The case represented one of the Supreme Court's early attempts to define the term “income.”[2] Justice Pitney's description of income as “the gain derived from capital, from labor, or from both combined” has been widely quoted, as has his comment that “the corporation tax act of 1909 was not intended to be and is not, in any proper sense, an income tax law.”[3][4] The case has been cited (unsuccessfully) in such cases as Hill v. United States and Cameron v. Internal Revenue Service, in support of the argument that a tax on an individual's income is unconstitutional, even though the decision in Stratton did not rule either corporate or individual income tax unconstitutional.