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HELVERING v. CANFIELD

No. 158.

291 U.S. 163 (1934)

54 S.Ct. 368

78 L.Ed. 706

HELVERING, COMMISSIONER OF INTERNAL REVENUE v. CANFIELD.

Supreme Court of United States.

Decided January 15, 1934.

Attorney(s) appearing for the Case

Mr. H. Brian Holland, with whom Solicitor General Biggs and Messrs. Sewall Key and Andrew D. Sharpe were on the brief, for the Commissioner of Internal Revenue.

Mr. Edwin H. Cassels, with whom Messrs. Barry Gilbert and Adolphus E. Graupner were on the brief, for Canfield and Thorsen.

MR. CHIEF JUSTICE HUGHES delivered the opinion of the Court.

These cases present the question of the construction of the following provisions of § 201 of the Revenue Act of 1921, 42 Stat. 228:

"Sec. 201. (a) That the term `dividend' when used in this title . . . means any distribution made by a corporation to its shareholders or members, whether in cash or in other property, out of its earnings or profits accumulated since February 28, 1913, . . .

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