Heyward v. United States

BRYAN, Circuit Judge.

On November 22, 1919, W. J. Marshall and R. L. Crandall dissolved the W. J. Marshall Company, a partnership, under which name they had for several years, including the year 1917, been engaged in business, and organized the W. J. Marshall Company, a corporation, with a capital stock of $100,000. Marshall and Crandall divided up between themselves partnership assets of the value of $18,000, transferred the remainder of such assets to the corporation, and received in return its capital stock of the par value of $95,000, in proportion to their interests in the partnership.…