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Taxation - Income Tax - Improvements Made By Lessee As Income To Lessor, Ralph E. Helper
Taxation - Income Tax - Improvements Made By Lessee As Income To Lessor, Ralph E. Helper
Michigan Law Review
The recent decision of the Supreme Court of the United States in M. E. Blatt Co. v. United States has fairly settled the conflict that has ranged for over twenty years between the Commissioner of Internal Revenue and the Board of Tax Appeals on one side, and the courts on the other. The commissioner's contention that improvements made by a lessee should be taxed as income to the lessor was denied, and by dictum the Court approved the reasoning of Judge Learned Hand in Hewitt Realty Co. v. Commissioner, wherein he said that the judicial concept of "income" did …
Taxation - Income Tax - Exempt Reorganizations - When Is A Reorganization Bona Fide Under The Rule Of Gregory V. Helvering, Ralph E. Helper
Taxation - Income Tax - Exempt Reorganizations - When Is A Reorganization Bona Fide Under The Rule Of Gregory V. Helvering, Ralph E. Helper
Michigan Law Review
An individual wished to buy certain patents from a corporation, and at his instigation, the corporation transferred them to a newly-organized patent holding company, which issued its shares directly to the stockholders of the transferor corporation. On discovery of disadvantages from this scheme, the buyer requested that the new corporation be dissolved and that the patents be assigned by the original patentee individually. Petitioner and all other shareholders sold their stock in the new corporation to the patentee in exchange for his notes, and he dissolved the corporation, receiving the patents on liquidation. The patents were then sold for cash, …