INSURANCE & TITLE GUARANTEE CO. v. COM'R OF INTERNAL REVENUE

No. 9.

36 F.2d 842 (1929)

INSURANCE & TITLE GUARANTEE CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

December 16, 1929.


Attorney(s) appearing for the Case

Hugh Satterlee, of New York City (A. S. Weill and Walter C. Blakely, both of Philadelphia, Pa., and Albert S. Lisenby, of Washington, D. C., of counsel), for petitioner.

Sewall Key, of Washington, D. C., and Norman D. Keller, of Pittsburgh, Pa. (C. M. Charest, Gen. Counsel, and P. S. Crewe, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before MANTON, L. HAND, and MACK, Circuit Judges.


L. HAND, Circuit Judge (after stating the facts as above).

We think that the difference in value between the shares and the cost of the property conveyed was income within the meaning of the Sixteenth Amendment. It is, of course, true that every change of form in a security is not treated as new property, as was once for all held in Eisner v. Macomber, 252 U.S. 189, 40 S.Ct. 189, 64 L. Ed. 521, 9 A. L. R. 1570, and the question of just...

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