-24-
We agree with respondent as to Zeve and Popovic; we agree
with petitioner as to Vecchio.
The term “private shareholder or individual” appears at
present in sections 170(c) (three places), 501(c) (eight places),
528(c)(1)(D), 833(c)(3)(A)(vi), 2055(a), 2522 (four places), and
4421(2)(B). This term has been unchanged since the Revenue Act
of 1924, Pub. L. 176, 68th Cong., 1st. Sess., ch. 234, 43 Stat.
253, 271, 282. The Revenue Act of 1921, Pub. L. 98, 67th Cong.,
1st Sess., ch. 136, 42 Stat. 227, 241, 253, used the term
“private stockholder or individual”, as did the prior Revenue
Acts back to the Tariff Act of 1913, Pub. L. 16, 63d Cong., 1st.
Sess., ch. 16, 38 Stat. 114, 172. The term “private stockholder
or individual” also appears in section 38 of the Tariff Act of
1909, commonly called the Corporation Excise Tax Act of 1909,
Pub. L. 5, 61st. Cong., 1st Sess., ch. 6, 36 Stat. 11, 113.
Neither of the parties has directed our attention to, and we have
not found, any statutory explanation of any of these terms. Our
examination of the legislative history of the Revenue Act of 1924
has not turned up any explanation of the shift from “stockholder”
to “shareholder”. We note that the Administration’s proposed
bill leading to the Revenue Act of 1924 retained the word
“stockholder”, while the bill as reported by the House Ways and
Means Committee used the word “shareholder”. We note also that
the term “private stockholder or individual” appears in paragraph
(2) of section 2055(a) (and its 1939 Code predecessor, section
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