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HELVERING v. FRIED

No. 186.

299 U.S. 175 (1936)

57 S.Ct. 150

81 L.Ed. 104

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. FRIED.

Supreme Court of United States.

Decided December 7, 1936.

Attorney(s) appearing for the Case

Assistant Attorney General Jackson, with whom Solicitor General Reed and Messrs. Sewall Key, Carlton Fox, and Charles A. Horsky were on the brief, for petitioner.

Mr. John J. Curtin for respondents.

MR. JUSTICE McREYNOLDS delivered the opinion of the Court.

Respondents in these two causes were partners as Albert Fired & Company, brokers, member of the New York Stock Exchange, with offices at 120 Broadway. When he undertook to determine their individual taxable profits during 1931, the Commissioner denied their claim that the firm's operations on the Exchange as a "Specialist" in thirteen stocks gave it the status of dealer therein, entitled to the privilege...

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