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Helvering Vs. Reynolds
Cites for this judgment
- US Supreme Court
- May 26, 1941
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U.S. 428 (1941) U.S. Supreme Court Helvering v. ReynoldsSearch
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U.S. 428 (1941) Helvering v. ReynoldsSearch
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in the case of those which the trustee had purchased. The Board of Tax Appeals sustained the Commissioner. Reynolds v. CommissionerSearch
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The government places considerable stress on Maguire v. CommissionerSearch
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ante, p. 313 U. S. 11 , and Helvering v. CampbellSearch
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as held in Helvering v. SanSearch
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Page 313 U. S. 432 language is resolved by reference to explicit statements of Congressional purpose. Maguire v. CommissionerSearch
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Helvering v. CampbellSearch
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under the earlier Acts was of such a character ( Higgins v. CommissionerSearch
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the language in question was an adoption of its previous interpretation within the rule of such cases as United States v. Dakota-MontanaSearch
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mean that the prior construction has become so embedded in the law that only Congress can effect a change. Morrissey v. CommissionerSearch
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U. S. 344 , 296 U. S. 355 . And see Murphy Oil Co. v. BurnetSearch
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the prior rule or practice through exercise by the administrative agency of its continuing rulemaking power. Helvering v. WilshireSearch
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until after the transactions in question had been consummated is immaterial. Cf. Manhattan General Equipment Co. v. CommissionerSearch
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interpretation. We think it was. However unambiguous that word might be as respects other transactions ( Helvering v. SanSearch
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supra, p. 313 U. S. 22 . As stated by Judge Arant in Augustus v. CommissionerSearch
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See Maguire v. CommissionerSearch
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Opposed to the decision below are Van Vranken v. HelveringSearch
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Cary v. HelveringSearch
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Archbold v. HelveringSearch
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F.2d 1005 -- all from the Second Circuit, and Augustus v. CommissionerSearch
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Pringle v. CommissionerSearch
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Hopkins v. CommissionerSearch
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F.2d 11. Cf. Lane v. CorwinSearch
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MR. JUSTICE ROBERTS, dissenting. I disagreed with the decisions of the Court in Maguire v. CommissionerSearch
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ante, p. 313 U. S. 1 , Helvering v. GambrillSearch
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might never enjoy it, he is to be treated as having acquired it. A contrary conclusion is required by Helvering v. SanSearch
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This was the section which was construed in Maguire v. CommissionerSearch
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Lane v. CorwinSearch
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Pringle v. CommissionerSearch
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Anchor Realty and Investment Co. v. BeckerSearch
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F.Supp. 22, aff'd, Becker v. AnchorSearch
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Warner v. CommissionerSearch
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Beers v. CommissionerSearch
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See Hartley v. CommissionerSearch
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McKinney v. UnitedSearch
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For the language of the section, see Note 5, Maguire v. CommissionerSearch
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U.S. Supreme Court Helvering v. ReynoldsSearch
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the Commissioner. Reynolds v. CommissionerSearch
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Maguire v. CommissionerSearch
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and Helvering v. CampbellSearch
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Helvering v. SanSearch
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Higgins v. CommissionerSearch
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United States v. Dakota-MontanaSearch
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Morrissey v. CommissionerSearch
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Helvering v. WilshireSearch
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Cf. Manhattan General Equipment Co. v. CommissionerSearch
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