United States Supreme Court Cases & Opinions

U.S. Supreme Court

Helvering v. San Joaquin Fruit & Investment Co., 297 U.S. 496 (1936)

Helvering v. San Joaquin Fruit & Investment Co.

No. 379

Argued February 13, 1936

Decided March 2, 1936

297 U.S. 496

Syllabus

1. Language used in tax statutes should be read in its ordinary and natural sense. P. 297 U. S. 499.

2. Under provision of the Revenue Acts of 1921, 1924, 1926, and 1928, for determining gain or loss from the sale of property, held that real property purchased under an option contained in a lease was "acquired" at the time of the conveyance to the optionee, and not at the time of the making of the lease. P. 297 U. S. 499.

3. The exercise of the option and the conveyance of the property did not constitute a conversion of two capital assets (the option and the purchase money) into a new capital asset (the land). P. 297 U. S. 500.

77 F.2d 723 reversed.

Certiorari, 296 U.S. 561, to review a judgment reversing a decision of the Board of Tax Appeals, 28 B.T.A. 395, which approved a determination of deficiency in income tax.