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HELVERING v. WATTS

No. 184.

296 U.S. 387 (1935)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. WATTS.

Supreme Court of United States.

Decided December 16, 1935.

Attorney(s) appearing for the Case

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 petitioner.

Mr. Samuel Seabury, with whom Messrs. John F. McCabe, James P. Quigley, and Robert J. Heberle were on the brief, for respondents.

By leave of Court, Mr. Edward H. Green filed a brief as amicus curiae, supporting the contentions of respondents.

MR. JUSTICE McREYNOLDS delivered the opinion of the Court.

These causes involved deficiency assessments for income tax against the three respondents for the year 1924.

They were the sole stockholders of United States Ferro Alloys Corporation — herein Ferro Alloys — and the causes, alike in all essential particulars, were dealt with below in one opinion.

The respondents maintain that they exchanged all stock of Ferro Alloys for shares...

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