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HELVERING v. SAN JOAQUIN CO.

No. 379.

297 U.S. 496 (1936)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. SAN JOAQUIN FRUIT & INVESTMENT CO.

Supreme Court of United States.

Decided March 2, 1936.

Attorney(s) appearing for the Case

Assistant Attorney General Wideman, with whom Solicitor General Reed and Messrs. Sewall Key, John MacC. Hudson, and Frederick W. Dewart were on the brief, for petitioner.

Mr. George M. Naus, with whom Messrs. J.R. Sherrod and Joseph D. Peeler were on the brief, for respondent.

MR. JUSTICE ROBERTS delivered the opinion of the Court.

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 question is presented under the relevant sections of the Revenue Acts of 1921, 1924, 1926 and 1928.1

October 13, 1906, the Irvine Company leased to the San Joaquin Fruit Company...

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