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Commissioner v. Munter, 331 U.S. 210 (1947)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Commissioner v. Munter, 331 U.S. 210 (1947)
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Commissioner of Internal Revenue v. Munter No. 674 Argued April 10, 1947 Decided May 5, 1947 * 331 U.S. 210
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE THIRD CIRCUIT
Syllabus
1. Under Internal Revenue Code §§ 22(a), 115(a), (b), upon a reorganization of two corporations into a new corporation, accumulated earnings and profits of the predecessor corporations which are undistributed in the reorganization are deemed to be acquired by the successor corporation and, upon distribution by it, are taxable as income, notwithstanding the participation of new investors in the successor corporation. Pp. 215-216.
2. To what extent the accumulated earnings and profits of the predecessor corporations have been retained by the successor in this case is for the Tax Court to determine upon a factual analysis. Pp. 216-217.
157 F.2d 132 reversed.
The Tax Court sustained the Commissioner’s determination of deficiencies in respondents’ income taxes. 5 T.C. 108. The Circuit Court of Appeals reversed. 157 F.2d 132. This Court granted certiorari. 329 U.S. 709. Reversed and remanded, p. 217.
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Chicago:
U.S. Supreme Court, "Syllabus," Commissioner v. Munter, 331 U.S. 210 (1947) in 331 U.S. 210 331 U.S. 211. Original Sources, accessed August 30, 2025, http://www.originalsources.com/Document.aspx?DocID=97V61IXHVKJJ354.
MLA:
U.S. Supreme Court. "Syllabus." Commissioner v. Munter, 331 U.S. 210 (1947), in 331 U.S. 210, page 331 U.S. 211. Original Sources. 30 Aug. 2025. http://www.originalsources.com/Document.aspx?DocID=97V61IXHVKJJ354.
Harvard:
U.S. Supreme Court, 'Syllabus' in Commissioner v. Munter, 331 U.S. 210 (1947). cited in 1947, 331 U.S. 210, pp.331 U.S. 211. Original Sources, retrieved 30 August 2025, from http://www.originalsources.com/Document.aspx?DocID=97V61IXHVKJJ354.
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