compensation for personal service ... of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and the income derived from any source whatever. The Court held that "this language was used by Congress to exert in this field the full measure of its taxing power", id., and that "the Court has given a liberal construction to this broad phraseology in recognition of the intention of Congress to tax all gains except those specifically exempted." The Court then enunciated what is now understood by Congress and the Courts to be the definition of taxable income, "instances of undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion." Id. at 431. The defendant, in that case, suggested that a 1954 rewording of the tax code had limited the income that could be taxed, a position which the Court rejected, stating: The definition of gross income has been simplified, but no effect upon its present broad scope was intended. Certainly, punitive damages cannot reasonably be classified as gifts, nor do they come under any other exemption provision in the Code. We would do violence to the plain meaning of the statute and restrict a clear legislative attempt to bring the taxing power to bear upon all receipts constitutionally taxable were we to say that the payments in question here are not gross income. In Conner v. The United States, a couple had lost their home to a fire and had received compensation for their loss from the insurance company, partly in the form of hotel costs reimbursed. The U.S. District Court acknowledged the authority of the IRS to assess taxes on all forms of payment but did not permit taxation on the compensation provided by the insurance company, because unlike a wage or a sale of goods at a profit, this was not a gain. As the court noted, "Congress has taxed income, not compensation". By contrast, at least two federal courts of appeals have indicated that Congress may constitutionally tax an item as "income," regardless of whether that item is in fact income. See Penn Mutual Indemnity Co.