Helvering v. Minnesota Tea Co.

296 U.S. 378 (1935)

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Helvering v. Minnesota Tea Co.

United States Supreme Court
296 U.S. 378 (1935)

Facts

Minnesota Tea Company (plaintiff) (Minnesota) transferred substantially all of its assets to Grand Union Company. In exchange, Minnesota received from Grand Union a substantial amount of cash and voting trust certificates representing a substantial portion of Grand Union’s common stock. Both Minnesota and the Internal Revenue Service (IRS) (defendant) treated the transaction as a reorganization under federal tax law. However, Minnesota and the IRS disagreed as to the tax treatment of a portion of the transaction, and they brought their disagreement to the United States Board of Tax Appeals. The United States Board of Tax Appeals, on its own accord, ruled that the transaction was not a reorganization in the first place. The Circuit Court of Appeals for the Eighth Circuit reversed, and the government appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (McReynolds, J.)

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