UNITED STATES SUPREME COURT DECISIONS ON-LINE

Pursuant to a consolidation agreement, two corporations conveyed their property to a new corporation in return for shares of its capital stock, issued not to the two corporations, but directly to their stockholders in proportion to their holdings in those corporations.

Held:

That the transaction was subject to a stamp tax under § 800 of the Revenue Act of 1926 not only on the original issue of the shares, but also on the transfers necessarily involved, whereby the rights to receive the shares, inherent in the two corporations by operation of law, were transferred by the agreement lo the stockholders. P. 296 U. S. 62.

80 Ct.Cls. 809, 10 F.Supp. 130, affirmed.

Certiorari, 295 U.S. 727, to review a judgment of the Court of Claims denying recovery of money exacted by the United States as stamp taxes.