Arrowsmith v. Commissioner, 344 U.S. 6 (1952), is a landmark United States Supreme Court case regarding taxation.

The taxpayers (properly) reported the income from the liquidation as long-term capital gains, thus obtaining a preferential tax rate.

The Tax Court disagreed with the Commissioner and found it to be an ordinary business loss.

[4] However, the Supreme Court held treating the proceeds of the liquidation consistently did not violate this rule, as it in no way attempts to reopen or amend the tax filings from 1937 to 1940.

Text of Arrowsmith v. Commissioner, 344 U.S. 6 (1952) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress