Legal Opinion
Helvering v. Sprouse
Supreme Court of the United States
Decided April 5, 1943No. Nos. 22 and 66PublishedCited by 33 opinions
1Opinion of the CourtJustice Roberts
Certiorari was granted because the decisions below in the two cases conflict. They arise under § 115 (f) (1) of the Revenue Act of 1936.
“A distribution made by a corporation to its shareholders in its stock or in rights to acquire its stock shall not be treated as a dividend to the extent that it does not constitute income to the shareholder within the meaning of the Sixteenth Amendment to the Constitution.”
No. 22
The respondent owned voting common stock in an Oregon corporation which paid a ten per cent stock dividend in shares of non-voting common stock. The company had outstanding but two…
2Cases cited3 opinions
- Koshland v. HelveringSupreme Court of the United States · 1936
- Sprouse v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1941
- Strassburger v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1941
3Cited by33 opinions
- Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
- Chamberlin v. CommissionerCourt of Appeals for the Sixth Circuit · 1953
- Chamberlin v. CommissionerUnited States Tax Court · 1952
- Wiegand v. CommissionerUnited States Tax Court · 1950
- Daggitt v. CommissionerUnited States Tax Court · 1954
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