This case involved a dispute over the proper valuation for federal income tax purposes of a 1918 corporate dividend paid to the defendant in the form of bonds issued from the company's accumulated surplus and profits. The Commissioner of Internal Revenue assessed additional tax based on the par value of the bonds attributable to post-February 28, 1913 earnings, while the Board of Tax Appeals allowed taxation at par but permitted a deduction for the loss from selling the bonds below par. The court held that the taxable dividend amount was limited to the bonds' fair market value (78% of par) when received by the taxpayer, as that was the actual economic benefit, and rejected any separate loss deduction because the taxpayer never received or was entitled to the full par amount. Accordingly, the government could recover only the difference between the original deficiency claim and the amount already paid following the Board's decision, with interest at 6%.
This case involved a dispute over ownership of a patent application for a fire-extinguishing foam stabilizer filed by defendant Urquhart. The plaintiff company claimed equitable ownership because Urquhart invented it while employed as sales manager under a contract with the company's predecessor. The court ruled in favor of the defendant, dismissing the plaintiff's bill and finding no right to an assignment of the application. The reasoning was that the employment contract specified duties related to sales, not invention, and there was no express agreement requiring Urquhart to assign any inventions to the employer. Therefore, the inventions remained the property of the employee.
The case concerned Max Hassel, who was charged with bribing two Prohibition Bureau officers assigned to monitor his brewery for violations of the law. After the officers initiated contact and arranged payments to allow shipments of beer, a commissioner found probable cause and held Hassel for the grand jury; Hassel then sought habeas corpus relief. The court discharged him, holding that the evidence showed the officers had induced the bribery through their own suggestion and agency rather than merely detecting preexisting criminal intent. It reasoned that government agents may use decoys to uncover ongoing crimes but may not create new offenses to entrap suspects, as doing so violates public policy against sustaining convictions obtained by official incitement.
The case involved a British corporation suing a Danish ship owner for the return of prepaid freight after the vessel Fredensbro sank following a collision in the Delaware River, preventing delivery of a coal cargo from Philadelphia to Belfast under a charter party. The libelant sought recovery in admiralty court by attaching the raised vessel in Philadelphia. The court addressed exceptions challenging jurisdiction due to the foreign nationalities of the parties, the absence of the full charter party in the libel, and an arbitration clause requiring disputes to be resolved in London. The court held that it had jurisdiction because the vessel was within its territory, the U.S. Arbitration Act permits such proceedings in admiralty with seizure of the vessel, and related litigation was ongoing in the district, and therefore dismissed the exceptions.
This case involved a suit by J. N. Collins Co. against F. M. Paist Co. for alleged unfair competition in the packaging and sale of butter scotch candy. The plaintiff had developed a distinctive open "boat" package with a red, black, and yellow Scotch plaid design for its "Honey Scotch" product, which was sold at retail for five cents and displayed for quick pickup by customers. The defendant, after years of selling its own butter scotch in wrapped tablets, adopted a similar open boat package with red and blue stripes for its "Mackey Butter Scotch," leading the court to find that the overall appearance was likely to deceive casual or unwary purchasers who would mistake one for the other. The court ruled for the plaintiff, granting an injunction along with an accounting of profits and damages, on the grounds that the defendant's packaging simulated the plaintiff's in arrangement, coloring, and design in a manner calculated to trade on the plaintiff's established goodwill. The decision emphasized that the law protects traders from such imitation, deters dishonest competition, and safeguards the public from deception based on general appearance rather than close inspection.
The case involved a bankruptcy proceeding where the U.S. collector of internal revenue filed a claim for additional income taxes assessed against the bankrupt under the Revenue Acts of 1918 and 1921, based on an estimate derived from average net profit percentages of similar businesses applied to the bankrupt's gross sales records. The trustee objected to the claim, which had been assessed after the bankruptcy petition was filed, and the referee disallowed it following a hearing. On review, the district court affirmed the disallowance. The court reasoned that Section 64(a) of the Bankruptcy Act empowers it to determine the amount and legality of tax claims rather than deferring to the taxing authorities, and that the assessment method—relying on statistical averages from other taxpayers rather than the bankrupt's own books or extrinsic evidence of actual income—failed to establish the real taxable facts as required by the revenue statutes.