Fairmont Creamery Corporation v. Helvering

This is an income tax case. Petitioner is a Delaware corporation with its principal office in Omaha, Neb. Its board of directors adopted a resolution in April, 1929, inviting employees to subscribe to the corporation’s common capital stock. The price was to be $26 per share, of which $2 was to be paid in cash. The balance was to be evidenced by notes with interest at 6 per cent., payable quarterly, the principal of the notes to be payable at the rate of SO cents per share per month. The conditions of the sale were these:

1st, the shares were not to be transferred, assigned, or pledged until…