There is no other definition of income, period. Now on Dauberger, Appeals of Fred R. , et al. They actually used Lonsdale to overrule Eisner. Notice by the citations, Eisner is a supreme court case and Lonsdale is a Circuit Court case. Don't ever let any judge tell you a lower court opinion can overrule a higher court opinion such as Lonsdale overruling Eisner.
Labor is property.
The common business and callings of life, the ordinary trades and pursuits, which are innocuous in themselves, and have been followed in all communities from time immemorial, must, therefore, be free in this country to all alike upon the same conditions. The right to pursue them, without let or hindrance, except that which is applied to all persons of the same age, sex, and condition, is a distinguishing privilege of citizens of the United States, and an essential element of that freedom which they claim as their birthright. It has been well said that, 'The property which every man has is his own labor, as it is the original foundation of all other property, so it is the most sacred and inviolable. The patrimony of the poor man lies in the strength and dexterity of his own hands, and to hinder his employing this strength and dexterity in what manner he thinks proper, without injury to his neighbor, is a plain violation of the most sacred property. This case declared a regulatory law unconstitutional that required him to request permission to sell stock which he owned and to have a brokers license to buy stock and later sell it at a profit which he also owned.