Pennroad Corp. v. Ladner

DICKINSON, District Judge.

This case raises an interesting question of law dependent upon an ultimate fact finding. There are no evidentiary facts in controversy. The real problem is to get .the correct concept of a transaction.

Title 8 of the Revenue Act of 1926, § 800 et seq., Schedule A — 3, 44 Stat. 101, imposes a stamp tax upon every share of .stock made the subject of any “sales or agreements to sell or memoranda of sales or deliveries of, or transfers of legal title to shares or certificates of stock * * * or to rights to subscribe for or to receive such shares or certificates, whether…