United States v. Phellis

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.

United States v. Phellis
Argued October 11, 1921
Decided November 21, 1921
Full case nameUnited States v. C. W. Phellis
Citations257 U.S. 156 (more)
42 S.Ct. 63; 66 L. Ed. 180; 1921 U.S. LEXIS 1328
Holding
Shares in a subsidiary corporation issued to stockholders in the parent corporation are taxable as income.
Court membership
Chief Justice
William H. Taft
Associate Justices
Joseph McKenna · Oliver W. Holmes Jr.
William R. Day · Willis Van Devanter
Mahlon Pitney · James C. McReynolds
Louis Brandeis · John H. Clarke
Case opinions
MajorityPitney, joined by Taft, McKenna, Holmes, Day, Brandeis, Clarke
DissentMcReynolds, joined by Van Devanter

See also

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Further reading

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  • Beale, Joseph H. (1923). "Stockholders and the Federal Income Tax". Harvard Law Review. 37 (1): 1–14. doi:10.2307/1328405. JSTOR 1328405.
  • Powell, Thomas Reed (1922). "Income from Corporate Dividends". Harvard Law Review. 35 (4): 363–392. doi:10.2307/1328647. JSTOR 1328647.
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