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UNITED STATES v. DAVIS

No. 282.

397 U.S. 301 (1970)

UNITED STATES v. DAVIS ET UX.

Supreme Court of United States.

Decided March 23, 1970

Attorney(s) appearing for the Case

Solicitor General Griswold argued the cause for the United States. With him on the brief were Assistant Attorney General Walters, Matthew J. Zinn, and William L. Goldman.

William Waller argued the cause for respondents. With him on the brief was Robert G. McCullough.

MR. JUSTICE MARSHALL delivered the opinion of the Court.

In 1945, taxpayer1 and E. B. Bradley organized a corporation. In exchange for property transferred to the new company, Bradley received 500 shares of common stock, and taxpayer and his wife similarly each received 250 such shares. Shortly thereafter, taxpayer made an additional contribution to the corporation, purchasing 1,000 shares of preferred stock at a par value of $25 per share...

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