United States Radiator Corporation, Appellant v. the State of New York, Respondent

Summary

The New York Court of Appeals affirmed the lower courts, holding that the certificates issued by the voting trust company constituted a taxable transfer of corporate stock under section 270 of the Tax Law. The court reasoned that the tax applies to the transaction of transfer, not to the stock itself, and that the issuance of the certificates represented a transfer of shares from the corporations to their shareholders.