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Helvering v. San Joaquin Fruit & Investment Co., 297 U.S. 496 (1936)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Helvering v. San Joaquin Fruit & Investment Co., 297 U.S. 496 (1936)
Helvering v. San Joaquin Fruit & Investment Co. No. 379 Argued February 13, 1936 Decided March 2, 1936 297 U.S. 496
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE NINTH CIRCUIT
Syllabus
1. Language used in tax statutes should be read in its ordinary and natural sense. P. 499.
2. Under provision of the Revenue Acts of 1921, 1924, 1926, and 1928, for determining gain or loss from the sale of property, held that real property purchased under an option contained in a lease was "acquired" at the time of the conveyance to the optionee, and not at the time of the making of the lease. P. 499.
3. The exercise of the option and the conveyance of the property did not constitute a conversion of two capital assets (the option and the purchase money) into a new capital asset (the land). P. 500.
77 F.2d 723 reversed.
Certiorari, 296 U.S. 561, to review a judgment reversing a decision of the Board of Tax Appeals, 28 B.T.A. 395, which approved a determination of deficiency in income tax.
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Chicago: U.S. Supreme Court, "Syllabus," Helvering v. San Joaquin Fruit & Investment Co., 297 U.S. 496 (1936) in 297 U.S. 496 Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=1183Z94VX35TUQ1.
MLA: U.S. Supreme Court. "Syllabus." Helvering v. San Joaquin Fruit & Investment Co., 297 U.S. 496 (1936), in 297 U.S. 496, Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=1183Z94VX35TUQ1.
Harvard: U.S. Supreme Court, 'Syllabus' in Helvering v. San Joaquin Fruit & Investment Co., 297 U.S. 496 (1936). cited in 1936, 297 U.S. 496. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=1183Z94VX35TUQ1.
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