Legal Opinion · Dissent
Hercules Gasoline Co. v. Commissioner
Supreme Court of the United States
Decided January 2, 1946No. 93Published
1DissentJustice Reed
Accepting Helvering v. Northwest Steel Mills, 311 U. S. 46, completely, I am unable to agree that this contract with preferred stockholders was other than a “routine contract dealing with ordinary debts.” Certainly this is not an instance of a “statutory obligation,” which are the words used in the Northwest case to describe the antithesis of the contract covered. “Routine” and “ordinary,” as *431used in Northwest, do not imply to me anything more than an express contract, executed in accordance with §26 (c) (1).
The exemption provisions of § 26 (c) make no exceptions because the debt of the…
2Cases cited6 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Budd International Corp. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1944
- Lehigh Structural S. Co. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1942
- Eljer Co. v. CommissionerCourt of Appeals for the Third Circuit · 1943
- Rex-Hanover Mills Co. v. United StatesUnited States Court of Claims · 1944
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