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Eisner v. Macomber, 252 U.S. 189 (1920), was a tax case before the United States Supreme Court that is notable for the following holdings:A pro rata stock dividend where a shareholder received no actual cash or other property and retained the same proportionate share of ownership of the corporation as was held prior to the dividend by the shareholder was not income to the shareholder under the Sixteenth Amendment.
An income tax that was imposed by the Revenue Act of 1916 on such a dividend was unconstitutional even if the dividend indirectly represented accrued earnings of the corporation.
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