Koshland v. Helvering

The writ of certiorari was granted in this ease to resolve a conflict between the decision below 1 and one by the Circuit Court of 'Appeals for the Sixth Circuit. 2

The question is whether, under the Revenue Acts of 1926 and 1928, a taxpayer who purchases cumulative non-voting preferred shares of a corporation upon which a dividend is subsequently paid in common voting shares, must, upon a sale or other disposition of the preferred shares, apportion their cost between preferred and common for the purpose of determining gain or loss.

The petitioner, in 1924 and 1926, purchased preferred stock of…