Helvering v. Chester N. Weaver Co.

delivered .the opinion of the Court.

The question to be decided is whether payments received by a corporation as a stockholder in another corporation, upon the latter’s complete liquidation, are to be treated as payments upon a sale or exchange of the stock under § 23 (r) (1) of the Revenue Act of 1932, 47 Stat. 169, which allows the deduction of losses from sales or exchanges of stock, not held for more than two years, only to the extent of the gains from such sales or exchanges.

On August 9, 1932, respondent, a California corporation, purchased shares of stock in another corporation. In the…