Louis Brandeis

“ The government concedes now that taxes are not payable on Nelson's alleged transfer to himself of his 13,173 shares which were to go to the bankers. The tax challenged is that on the alleged transfer to Nelson of the right to receive the 61,365 shares which the other stockholders contributed. ”

“ In each case, the person originally entitled to receive the certificate directed, for his own convenience and purposes, that it be issued in the name of a nominee. It is argued in the Automatic Washer Company Case, that the stockholders of the old company never acquired the 'right to receive' that portion of their stock which was designed for transfer to the bankers; that they did not become entitled to receive shares in the new company until the contract with it was made on September 27th ”

“ Notes
↑ In the eventual determination of the pro rata contribution by the old company's stockholders to the stock to be sold to the bankers, the amount of preferred to be sold was reduced to 34,538 shares. See Automatic Washer Co. v. United States (Ct.Cl.) ”