LeTulle v. Scofield

308 U.S. 415 (1940)

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LeTulle v. Scofield

United States Supreme Court

308 U.S. 415 (1940)

Facts

V. L. LeTulle (plaintiff) was the sole shareholder of the Gulf Coast Irrigation Company (the irrigation company). The irrigation company entered into an agreement with the Gulf Coast Water Company (the water company) under which all properties owned by the irrigation company would be conveyed to the water company for $50,000 in cash and $750,000 in bonds. Following a liquidating dividend to LeTulle, the irrigation company was dissolved. The Internal Revenue Service (IRS) assessed taxes against LeTulle for the dividend and the gain realized by the irrigation company. LeTulle paid the tax and brought suit against IRS collector Frank Scofield (defendant) for a refund. The district court found in favor of LeTulle, ruling that the transaction had constituted a nontaxable corporate reorganization. Scofield appealed. The circuit court of appeals reversed. LeTulle appealed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Roberts, J.)

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