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NELSON CO. v. HELVERING

No. 61.

296 U.S. 374 (1935)

JOHN A. NELSON CO. v. HELVERING, COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided December 16, 1935.

Attorney(s) appearing for the Case

Mr. J.S. Seidman for petitioner.

Mr. J. Louis Monarch, with whom Solicitor General Reed, Assistant Attorney General Wideman, and Messrs. James W. Morris and Sewall Key were on the brief, for respondent.

Mr. JUSTICE McREYNOLDS delivered the opinion of the Court.

The petitioner contests a deficiency income assessment made on account of alleged gains during 1926. It claims that the transaction out of which the assessment arose was reorganization within the statute. Section 203, Revenue Act, 1926, c. 27, 44 Stat. 9, 11, is relied upon. The pertinent parts are in the margin of the opinion in Helvering v. Minnesota Tea...

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