George A. Hormel & Co. v. United States

NORDBYE, District Judge.

This matter was submitted on a stipulation of facts. There is but one issue to be determined; '.namely, the right of the defendant to tax a' transaction which it contends was a. “transfer of a right to receive shares or certificates of stock as provided for in section 800 of the Revenue Act of 1926, 26 USCA § 901, Schedule A-3.” Briefly, the facts as disclosed by the stipulation may be stated as follows:

George A. Hormel & Co., a Minnesota corporation, on or about September 1, 1928, caused a notice to be sent to its stockholders of a corporate meeting on September 18,…