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HELVERING v. PFEIFFER

No. 29.

302 U.S. 247 (1937)

58 S.Ct. 159

82 L.Ed. 231

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. PFEIFFER.

Supreme Court of United States.

Decided December 6, 1937.

Attorney(s) appearing for the Case

Assistant Attorney General Jackson argued the cause, and Solicitor General Reed, Assistant Attorney General Morris, Messrs. Sewall Key and Morton K. Rothschild were on the brief, for petitioner.

Messrs. John C. Altman and A.L. Nash argued the cause for respondent. With Mr. Altman on the brief was Mr. Roger S. Baldwin.

By leave of Court, Messrs. J. Harry Covington, John Thomas Smith and Paul E. Shorb filed a brief as amici curiae, in support of the respondent.

MR. JUSTICE BRANDEIS delivered the opinion of the Court.

This case presents questions of income taxation applicable to stock dividends.

In 1931, Annie M. Pfeiffer, a holder of common stock in William R. Warner Corporation, received as a dividend thereon 6,291 1/4 shares of its preferred stock. She also received from the corporation in that year $200,000 cash in exchange for 2,000 shares of its preferred stock which she had received as a dividend in 1928. In...

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