Legal Opinion
Helvering v. Salvage
Supreme Court of the United States
Decided January 13, 1936No. Nos. 173 and 280PublishedCited by 167 opinions
1Opinion of the CourtJustice McReynolds
These cross writs' bring, up a judgment of the Circuit Court of Appeals, 2nd Circuit, which disapproved a deficiency assessment for 1929 income; and authorized recovery for overpayment below the taxpayer’s claim.
The petition for certiorari in No. 173 asserts: “The question is — Whether the taxpayer is estopped to claim that the difference between the market value of the 1,500 shares as of December 30, 1922 and their cost to him constituted taxable income to him for 1922; and hence that the fair market value of these shares, and not their cost, is the basis .to be used in measuring the gain…
2Cases cited1 opinion
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
3Cited by167 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Helvering v. GowranSupreme Court of the United States · 1937
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- Commissioner of Internal Revenue v. Union Pac. R. Co.Court of Appeals for the Second Circuit · 1936
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