Union Oil Co. of California v. United States

I do not 'agree with the decision of the court. The facts are stipulated and involve the merger of Union Oil Company of California (Union) and Pure Oil Company, 'a corporation, of Ohio ¡(Pure). Pure was merged or absorbed into Union. Thus, 'Union became the “acquiring” corporation and Pure became the “absorbed” corporation. The parties agree that the merger was governed by the laws of Ohio.

After the merger, Union issued stock in the new corporation on a pro rata basis previously agreed upon to its old stockholders and to the old stockholders of Pure. Union paid *125documentary stamp taxes in the…