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Groman v. Commissioner, 302 U.S. 82 (1937)
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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.
Groman v. Commissioner, 302 U.S. 82 (1937)
Groman v. Commissioner or Internal Revenue No. 21 Argued October 21, 22, 1937 Decided November 8, 1937 302 U.S. 82
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE SEVENTH CIRCUIT
Syllabus
1. Section 112(i)(2) of the Revenue Act of 1928 declaring that the term party to a reorganization "includes" a corporation resulting from a reorganization, and both corporations when one acquires specified proportions of stock of another, is not an exclusive definition, but rather is intended to enlarge the meaning of the term beyond its ordinary connotation. P. 85.
2. Pursuant to an agreement between a corporation (G) and shareholders of another corporation (I): -- G formed a new corporation (O), subscribing for its common stock and paying for it with cash and G’s own preference shares; I’s shareholders sold their shares to O and received from O a consideration made up of preference shares of G, and of O and cash; I then transferred its assets to O, and was dissolved. Held that G was not "a party" to the reorganization, and that the shares of G’s preference stock received by I shareholders from O were a basis for computing taxable gain. Revenue Act of 1928, § 112. P. 88.
86 F.2d 670 affirmed.
Certiorari, 301 U.S. 677, to review a judgment overruling an order of the Board of Tax Appeals and sustaining an income tax deficiency assessment.
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Chicago: U.S. Supreme Court, "Syllabus," Groman v. Commissioner, 302 U.S. 82 (1937) in 302 U.S. 82 302 U.S. 83. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=CAFIKX779QUEQYR.
MLA: U.S. Supreme Court. "Syllabus." Groman v. Commissioner, 302 U.S. 82 (1937), in 302 U.S. 82, page 302 U.S. 83. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=CAFIKX779QUEQYR.
Harvard: U.S. Supreme Court, 'Syllabus' in Groman v. Commissioner, 302 U.S. 82 (1937). cited in 1937, 302 U.S. 82, pp.302 U.S. 83. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=CAFIKX779QUEQYR.
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