PENNROAD CORPORATION v. LADNER

No. 18578.

21 F.Supp. 575 (1937)

PENNROAD CORPORATION v. LADNER, Former Collector of Internal Revenue.

District Court, E. D. Pennsylvania.

June 22, 1937.


Attorney(s) appearing for the Case

George G. Chandler and Robert T. McCracken, both of Philadelphia, Pa., for plaintiff.

Thomas J. Curtin, Asst. U. S. Atty., of Philadelphia, Pa., J. Cullen Ganey, U. S. Atty., of Bethlehem, Pa., and E. F. McMahon, Sp. Asst. to the Atty. Gen., for defendant.


DICKINSON, District Judge.

This case raises an interesting question of law dependent upon an ultimate fact finding. There are no evidentiary facts in controversy. The real problem is to get the correct concept of a transaction.

Title 8 of the Revenue Act of 1926, § 800 et seq., Schedule A — 3, 44 Stat. 101, imposes a stamp tax upon every share of stock made the subject of any "sales or agreements to sell or memoranda of sales or deliveries of,...

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