Legal Opinion
Helvering v. San Joaquin Fruit & Investment Co.
Supreme Court of the United States
Decided March 2, 1936No. 379PublishedCited by 164 opinions
1Opinion of the CourtJustice Roberts
Is real property “acquired,” within the meaning of the revenue acts, when a lease is made containing an option to purchase, or when the option is exercised? The ques tion is presented under the relevant sections of the Revenue Acts of 1921, 1924, 1926 and 1928.
October 13,1906, the Irvine Company leased to the San Joaquin Fruit Company one thousand acres, part of a much larger tract, of bare unirrigated land in California. The lessor was wholly owned by one Irvine, and the lessee was organized by two experienced men who together with Irvine subscribed its capital, in the hope that planting,…
2Cases cited14 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Willard v. TayloeSupreme Court of the United States · 1870
- Reinecke v. SmithSupreme Court of the United States · 1933
- Richardson v. HardwickSupreme Court of the United States · 1882
- Smith v. BanghamCalifornia Supreme Court · 1909
9 more not listed; retrieve them via the Exa API.
3Cited by164 opinions
- Commissioner v. SmithSupreme Court of the United States · 1945
- Toll Bros., Inc. v. Township of ReadingtonCourt of Appeals for the Third Circuit · 2009
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Stolk v. CommissionerUnited States Tax Court · 1963
- Vaira v. CommissionerUnited States Tax Court · 1969
159 more not listed; retrieve them via the Exa API.