Fulman v. United States

The Court’s opinion, with commendable candor, recognizes that logic supports petitioners’ position:

“[We do] not . . . deny the logical force of petitioners’ *540argument that, since the purpose of the personal holding company tax is to force individuals to include personal holding company income in their individual returns, the corporate distributor should get a deduction at the corporate level equal to the income generated by the distribution at the shareholder level as defined by § 301, that is, the fair market value of the appreciated property in this case. See 26 U. S. C. §301 (b)(1)(A).”…