In Commissioner of Internal Revenue v. Glenshaw Glass Co., 348 U.S. 426, 75 S. Ct. 473, 99 L. Ed. 483 (1955), the Court addressed whether money received as exemplary damages for fraud or as the punitive two-thirds portion of a treble-damage antitrust recovery is subject to the federal gross income tax pursuant to I.R.C. 22(a)(1954). Section 22(a), a predecessor to I.R.C. 61(a), defined gross income in part to include "gains, profits, and income from salaries, wages, or compensation for personal service . . . of whatever kind and in whatever form paid, or . . . gains or profits and income derived from any source whatever." The Court initially observed that it "has frequently stated that this language was used by Congress to exert in this field ' the full measure of its taxing power.'" Glenshaw Glass, 348 U.S. at 429, 75 S. Ct. at 476 . T he Court further noted that it "has given a liberal construction to this broad phraseology in recognition of the intention of Congress to tax all gains except those specifically exempted." Id., 348 U.S. at 430, 75 S. Ct. at 476 . The Court reviewed its holding in Eisner, stating that its definition of income in that case served a useful purpose by distinguishing gain from capital but that such definition "was not meant to provide a touchstone to all future gross income questions." Id., 348 U.S. at 431, 75 S. Ct. at 477. The Court continued by observing that, in the case before it, "we have instances of undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion." Id. Ultimately, the Court concluded that the damages in question were subject to the gross income tax. See id., 348 U.S. at 433, 75 S. Ct. at 478. In so doing, the Court noted the legislative history of the revenue code, which labeled the statutory gross income tax as being "all-inclusive." Id., 348 U.S. at 432, 75 S. Ct. at 477. Moreover, the Court stated that it "would do violence to the plain meaning of the statute and restrict a clear legislative attempt to bring taxing power to bear upon all receipts constitutionally taxable were we to say that the payments in question here are not gross income." Id., 348 U.S. at 433, 75 S. Ct. at 477-78.