United States v. Whitridge, 231 U.S. 144 (1913)
U.S. Supreme CourtUnited States v. Whitridge, 231 U.S. 144 (1913)
United States v. Whitridge
Nos. 466, 467
Argued October 21, 1913
Decided November 10, 1913
231 U.S. 144
The Corporation Tax Law of 1909 was adopted before the ratification of the Sixteenth Amendment, and imposed an excise tax on the doing of business by corporations, and not in any sense a tax on property or upon income merely as such. Flint v. Stone-Tracy Co., 220 U. S. 107. The Corporation Tax Law does not in terms impose a tax upon corporate property or franchises as such, nor upon the income arising from the conduct of business unless it be carried on by the corporation.
The Act of August 5, 1909, c. 6, § 38, 36 Stat. 11, 112, does not impose a tax upon the income derived from the management of corporate property by receivers under the conditions of this case.
193 F. 289, 198 F. 774, affirmed.
The facts, which involve the construction of the federal Corporation Tax Act and the determination of whether the same imposed a tax upon the income derived from the management of corporate property by receivers appointed by the court, are stated in the opinion.