Morley v. F. L. Putnam & Co.

1 Mass. App. Div. 530
CourtMassachusetts District Court, Appellate Division
DecidedNovember 16, 1936
StatusPublished

This text of 1 Mass. App. Div. 530 (Morley v. F. L. Putnam & Co.) is published on Counsel Stack Legal Research, covering Massachusetts District Court, Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morley v. F. L. Putnam & Co., 1 Mass. App. Div. 530 (Mass. Ct. App. 1936).

Opinions

Carr, J.

This is an action of contract to recover $580.00 paid to the defendant for twenty shares of the capital stock of the Farr Alpaca Company, alleged to have been sold to the plaintiff in violation of the Sale of Securities Act. The case was tried on an agreed statement of facts each party reserving the right to introduce further evidence. From this agreed statement it appears that the Farr Alpaca Co. was a Massachusetts business corporation, manufacturing textiles; that before June 8, 1933, its outstanding stock consisted of 140,000 shares of capital stock of a par value of $100 each, or a total of $14,000,000; that on June 8, 1933, the par value of the stock was reduced from $100 to $50 by transferring $7,000,000 from “capital stock” to “surplus” on the liability side of the books of the company and by stamping outstanding certificates, “The par value has been reduced to fifty dollars”. Thereafter the stock of the company consisted of 140,000 shares of capital stock of a par value of $50 each, or a total of $7,000,000. [532]*532As the old certificates were surrendered for transfer, new certificates were issued which bore on their face the words, “Par value fifty dollars each”. The plaintiff received a certificate in this form. It also appears that due notice of intention to sell the stock with a par value of $100 was given, in accordance with the Sale of Securities Act, before the sale to the plaintiff, but that no such notice as to the stock with a par value of $50 was given until after the sale. The sale was not within any of the exemptions specified in sections 3 and 4 of the 1932 amendment of the act, unless it came within the provisions of section 3 (a) relating to an isolated sale. The defendant and its predecessors have been in business as brokers in Boston since 1923.

In disposing of a ruling requested by the plaintiff to the effect that the capital stock of the company with a par value of fifty dollars was a different security from the capital stock with a par value of one hundred dollars, the trial judge ruled that “it is the same stock”. The judge also found that the stock in question was qualified for sale in Massachusetts; that the stóck was sold by the defendant as owner; that it was an isolated sale; and that the defendant had not sold Farr Alpaca stock aside from this transaction for many years.

As the shares with a par value of $100 were qualified for sale under the Sale of Securities Act, and as the stock with a par value of $50 was qualified only if it was the same security as the $100 share, the first question raised by the appeal is whether the share with the reduced par value is the same security as the other.

The argument that the shares with the $100 and with the $50 par value are the same security rests on the proposition that after the change the several stockholders still held the same proportionate interests in the corporation. There are undoubtedly situations where the increase or decrease in [533]*533the paper capital of a corporation makes no change in the rights of the stockholders, cf. Hood Rubber Co. v. Commonwealth, 238 Mass. 369.

To determine whether this is always so the distinction between capital stock and shares of capital stock and between capital stock and surplus profits must be borne in mind. This has been concisely stated in a decision of the United States Supreme Court, speaking in this instance of a bank. ‘ ‘ The capital stock is the money paid or authorized or required to be paid in as the basis of the business' of the bank, and the means of conducting its operations. It represents whatever it may be invested in. If a large surplus be accumulated and laid by, that does not become a part of it. The amount authorized cannot be increased without proper legal authority. ... No power to increase or diminish it belongs inherently to the corporation. It is a trust fund, held by the corporation as a trustee.” . .. . “The shares of the capital stock are usually represented by certificates. Eivery holder is a cestui que trust to the extent of his ownership. The shares are held and may be bought and sold and taxed like other property. Each share represents an aliquot part of the capital stock. But the holder cannot touch a dollar of the principal. He is entitled only to share in the dividends and profits. Upon the dissolution of the institution, each shareholder is entitled to a proportional share of the residuum after satisfying all liabilities.” Farrington v. Tennessee, 95 U. S. 679, 686, et seq. 5 Thompson on Corporations, 3rd ed., p-r 305.

“Ordinarily dividends can be declared and paid only out of the profits or surplus earnings of the corporation. The rule of law that requires corporations to preserve their capital intact is alone sufficient to prevent the corporation from paying dividends except out of the profits.” . . .

2 Thompson on Corporations, 3rd ed., §5290, §5297. [534]*534But surplus may be turned into capital and capital into surplus.

In determining whether a stock dividend, declared and issued by a corporation, after the Massachusetts income tax law of 1916, Chap. 269, went into effect, out of profits earned before the act took effect, was taxable, the court said:

“The stock dividend was declared strictly out of an accumulation of earnings applied to business uses and not out of increased market value of capital investment. See Thayer v. Burr, 201 N. Y. 155. That which the stockholder had before was a fractional interest in the property of the corporation. So far as concerned the accumulation of profits, there was a possibility that they might be paid out in whole or in part as a cash dividend by authority of the corporation. By the issue of the stock dividend thai[ possibility is ypne and the stockholder now1 has evidence of a permanent interest in the corporate enterprise of which he cannot be deprived. It is a thing different in kind from the thing which the stockholder owned before. From the viewpoint of the stockholder, he has received in the form of a dividend in stock a thing with which theretofore he could have no tangible dealings. The certificate for the new shares of stock representing the stock dividend may have a materially greater value than the less tactile right to a share in the accumulated profits Avhich he had before.

. The thing of value Avhich is taxed as income, namely the dividend in stock, did not come into his possession or right to possession until the year for which he is taxed. It is this thing of value which is taxable at the time when it comes into his right to possession.” Tax Commissioner v. Putnam, 227 Mass. 522, 535, 536.

On the other hand, “When the capital stock has been legally and properly reduced, the surplus over and above the amount of such capital stock as reduced, could properly [535]*535be distributed as a dividend”, pro Tided such reduced capital stock was not impaired. 2 Thompson, Corporations, 3rd ed., §5297.

Thus where the capital in the sense of shares was reduced under a New York statute it was said by the court, “But although this was the purpose of the act, yet it is possible that eases may occur where a corporation, having on hand actual, tangible capital, equal to the full nominal amount of its capital stock, may comply with the provisions of the act, and thereby diminish the nominal amount of its capital.

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Related

Farrington v. Tennessee
95 U.S. 679 (Supreme Court, 1878)
Seeley v. . New York National Exchange Bank of New York
78 N.Y. 608 (New York Court of Appeals, 1879)
Strong v. . Brooklyn Cross-Town R.R. Co.
93 N.Y. 426 (New York Court of Appeals, 1883)
Thayer v. . Burr
94 N.E. 604 (New York Court of Appeals, 1911)
Seeley v. New York National Exchange Bank
8 Daly 400 (New York Court of Common Pleas, 1878)
Page v. Whittenton Manufacturing Co.
97 N.E. 1006 (Massachusetts Supreme Judicial Court, 1912)
Commonwealth v. United States Worsted Co.
220 Mass. 183 (Massachusetts Supreme Judicial Court, 1915)
Bliss v. Bliss
221 Mass. 201 (Massachusetts Supreme Judicial Court, 1915)
Main v. County of Plymouth
223 Mass. 66 (Massachusetts Supreme Judicial Court, 1916)
Tax Commissioner v. Putnam
227 Mass. 522 (Massachusetts Supreme Judicial Court, 1917)
Hood Rubber Co. v. Commonwealth
131 N.E. 201 (Massachusetts Supreme Judicial Court, 1921)
Kneeland v. Emerton
183 N.E. 155 (Massachusetts Supreme Judicial Court, 1932)

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1 Mass. App. Div. 530, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morley-v-f-l-putnam-co-massdistctapp-1936.