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FOUNDERS GENERAL CO. v. HOEY

No. 398.

300 U.S. 268 (1937)

57 S.Ct. 457

81 L.Ed. 639

FOUNDERS GENERAL CORP. v. HOEY, COLLECTOR OF INTERNAL REVENUE.

Supreme Court of United States.

Decided March 1, 1937.

Attorney(s) appearing for the Case

Mr. Royal E.T. Riggs for petitioner in No. 398.

Mr. J.P. Jackson, with whom Solicitor General Reed, Assistant Attorney General Jackson, and Messrs. Sewall Key and George H. Zeutzius were on the brief, for respondent in No. 398 and petitioner in Nos. 331 and 330.

Mr. George K. Bowden for respondent in No. 331.

Mr. Jesse I. Miller for respondent in No. 330.

By leave of Court, Mr. Thaddeus G. Benton filed a brief in No. 330 on behalf of the Middle States Petroleum Corp., as amicus curiae, urging affirmance of the judgment below.

MR. JUSTICE BRANDEIS delivered the opinion of the Court.

These three cases present, in the main, the same question: When, at the instance of one entitled to receive stock, the certificates therefor are, at his request and for his convenience, issued by the corporation in the name of a nominee who receives no beneficial interest therein, does the transaction involve a transfer by the beneficial owner requiring a documentary stamp pursuant to § 800, Schedule A...

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