United States v. Phellis
| United States v. Phellis |
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Argued October 11, 1921
Decided November 21, 1921 |
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| Full case name |
United States v. C. W. Phellis |
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| Citations |
257 U.S. 156 (more) 42 S.Ct. 63 |
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| Holding |
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Shares in a subsidiary corporation issued to stockholders in the parent corporation are taxable as income. |
| Court membership |
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| Case opinions |
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| Majority |
Pitney, joined by Taft, McKenna, Holmes, Day, Brandeis, Clarke |
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| Dissent |
McReynolds, joined by Van Devanter |
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United States v. Phellis, 257 U.S. 156 (1921), was a decision by the United States Supreme Court, which held that shares in a subsidiary corporation issued to stockholders in the parent corporation were taxable as income.
See also
Further reading
External links
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Wikisource has original text related to this article:
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- Text of United States v. Phellis, 257 U.S. 156 (1921) is available from: Findlaw Justia
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| | Scope |
- Brushaber v. Union Pacific Railroad (1916)
- Stanton v. Baltic Mining Company (1916)
- Tyee Realty Co. v. Anderson (1916)
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| | Income | |
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| | Taxable corporate dividends |
- Lynch v. Turrish (1918)
- Southern Pacific Co. v. Lowe (1918)
- Lynch v. Hornby (1918)
- Peabody v. Eisner (1918)
- Eisner v. Macomber (1920)
- United States v. Phellis (1921)
- Rockefeller v. United States (1921)
- Merchants' Loan & Trust v. Smietanka (1921)
- Miles v. Safe Deposit Co. (1922)
- Cullinan v. Walker (1923)
- Weiss v. Stearn (1924)
- Marr v. United States (1925)
- Koshland v. Helvering (1936)
- Helvering v. Gowran (1937)
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| | Taxable corporate earnings |
- Edwards v. Cuba Railroad (1925)
- Burk-Waggoner Assoc. v. Hopkins (1925)
- Texas & Pacific Railway Co. v. United States (1932)
- Continental Tie & Lumber Co. v. United States (1932)
- Helvering v. Mitchell (1938)
- Helvering v. National Grocery (1938)
- Helvering v. Northwest Steel Mills (1940)
- Crane-Johnson Co. v. Helvering (1940)
- Commissioner v. Glenshaw Glass Co. (1955)
- General American Investors Co. v. Commissioner (1955)
- Commissioner v. Gillette Motor Co. (1960)
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| | Taxable gains | |
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| | Unlawful income |
- United States v. Sullivan (1927)
- Rutkin v. United States (1952)
- Commissioner v. Sullivan (1958)
- James v. United States (1961)
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| | Deductions and exemptions |
- Brushaber v. Union Pacific Railroad (1915)
- Burnet v. Sanford & Brooks Co. (1931)
- McLaughlin v. Alliance Ins. Co. (1932)
- Helvering v. Independent Life Ins. Co. (1934)
- Helvering v. Winmill (1938)
- Millinery Corp. v. Commissioner (1956)
- Tank Truck Rentals v. Commissioner (1958)
- Hoover Express Co. v. United States (1958)
- Cammarano v. United States (1959)
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| | Diminution of loss | |
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