Groman v. Commissioner
United States Supreme Court
302 U.S. 82 (1937)
Groman (plaintiff) and other shareholders of Metals Refining Company entered into a contract with Glidden Company under which Metals Refining would be merged into a subsidiary formed by Glidden. The shareholders assigned their Metals Refining stock to the subsidiary and in return received a combination of stock in Glidden, stock in the subsidiary, and cash. Metals Refining then transferred its remaining assets to the subsidiary and was dissolved, the final step in an event known as a forward triangular merger. Groman included the cash in his taxable income but excluded the stock on the reasoning that the merger had been a tax-free corporate reorganization. The Commissioner of Internal Revenue (the commissioner) (defendant) determined that Glidden was not a party to the reorganization as contemplated by federal statute and that the Glidden stock was taxable. Groman sought a redetermination before the Board of Tax Appeals. The board found in Groman’s favor. The commissioner appealed. The circuit court of appeals found in favor of the commissioner, and Groman appealed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Roberts, J.)
What to do next…
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 684,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
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.Learn about our approachRead more about Quimbee
Here's why 684,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 42,800 briefs, keyed to 988 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.