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Helvering v. Watts, 296 U.S. 387 (1935)
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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. Watts, 296 U.S. 387 (1935)
Helvering v. Watts No. 184 Argued November 20, 1935 Decided December 16, 1935 296 U.S. 387
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE SECOND CIRCUIT
Syllabus
1. Where stockholders owning all of the shares of corporation A exchanged them for stock in corporation B and mortgage bonds of corporation A guaranteed by Corporation B, there was a "reorganization" under § 203(h)(1)(A) of the Revenue Act of 1924, and, by the effect of § 203(b)(2), no taxable gain resulted notwithstanding the A corporation continued in business. Helvering v. Minnesota Tea Co., ante, p. 378. P. 388.
2. The transaction is within the description of reorganization set forth by Article 1574 of Treasury Regulations 65, applicable to the Revenue Act of 1924, and that this regulation is a proper interpretation of the Act is confirmed by the reenactment, without change, by Congress of the paragraph to which it refers. P. 389.
3. The bonds were "securities" within the meaning of § 203(b)(2) of the Act. P. 389.
75 F.2d 981 affirmed.
Certiorari to review a Judgment reversing a decision of the Board of Tax Appeals, 28 B.T.A. 1056, which sustained a deficiency assessment of income taxes.
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Chicago: U.S. Supreme Court, "Syllabus," Helvering v. Watts, 296 U.S. 387 (1935) in 296 U.S. 387 296 U.S. 388. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=JPAAQLFBU1JGGM9.
MLA: U.S. Supreme Court. "Syllabus." Helvering v. Watts, 296 U.S. 387 (1935), in 296 U.S. 387, page 296 U.S. 388. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=JPAAQLFBU1JGGM9.
Harvard: U.S. Supreme Court, 'Syllabus' in Helvering v. Watts, 296 U.S. 387 (1935). cited in 1935, 296 U.S. 387, pp.296 U.S. 388. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=JPAAQLFBU1JGGM9.
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