Reversed and remanded. The Railroad Retirement Tax Act of 1937 was enacted to provide pensions to railroad workers at a time when many railroads were on the brink of insolvency. Under the Act, railroads paid a tax based on employee incomes, but no tax was paid on payments made to employees in kind. To modernize the pension fund, stock options were adopted. Congress sought to tax the options. The Supreme Court held that employee stock options are not taxable under the Act because they are not money remunerations.