Quimbee logo
DMCA.com Protection Status
From our private database of 18,400+ case briefs...

Commissioner v. Segall

United States Court of Appeals for the Sixth Circuit
114 F.2d 706 (1940)


On October 2, 1931, Timken-Detroit Company and Silent Automatic Company agreed to merge. Under the terms of the transaction, Timken-Detroit would transfer its assets to Silent Automatic. The companies believed the transaction to be a non-taxable reorganization. In 1931, the companies prepared the documents necessary for the transaction but scheduled a closing date of January 2, 1932 to transfer title and possession. The Internal Revenue Service (IRS) (defendant) determined that the transaction was a sale subject to taxation for the year 1932. The companies appealed, and the Board of Tax Appeals found that the transaction did not constitute a sale. The IRS appealed.

Rule of Law


Holding and Reasoning (Arant, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 496,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 496,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,400 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial