Towne v. Eisner
United States Supreme Court
245 U.S. 418 (1918)
- Written by Eric Miller, JD
Facts
Henry Towne (plaintiff) was a stockholder in a corporation that voted to transfer $1,500,000 in retained earnings to its capital account and then issue 15,000 shares of stock as a dividend. Towne received 4,174.5 shares. Collector of Internal Revenue Mark Eisner (defendant) regarded the stock as equivalent to $417,450 in income. Eisner assessed a deficiency against Towne, who challenged the assessment in district court. The court found in favor of Eisner. Towne appealed. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Holmes, J.)
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