The Law of Promoters; a Treatise On the Law of Promoters of Private Corporations, Covering the Rights And Liabilities of Promoters, And Also the Rights And Liabilities of the Corporation And the Subscribers for And Purchasers of Its Shares, the Rights And

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W. R. Co. V. Tiernan, 37 Kan. 606, 54. 210 U. S. 206, 215, 28 Sup. Ct.
633, 15 Pac. 544. Also perhaps in 634, 52 L. Ed. 1025.
Watkins v. Mills, 114 N. X. App. 55. See ante, § 120, et seq.
Div. 903, 100 Supp. 1148. For the 56. Plaquemines Tropical Fruit facts of this ease, see ante, § 127, Co. v. Buck, 52 N. J. Eq. 219, 232- See also In re Darby, 1911, 1 K. B. 233, 27 Atl. 1094, 44 Am. & Bng.
95, 103, 80 L. J. K. B. 180, where Corp. Cas. 686; Pittsburg Mining Phillimore, J., said that he was not
... Co. v. Spooner, 74 Wis. 307, 322, 42 LAWFUL PROFITS. 267 subsequent shareholders are brought in as original subscribers or as purchasers from the promoters. The only manner in which these apparently unsubstantial distinctions can be accounted for, is that the rule against promoters' profits, while just in theory, often works a great hardship in practice. It is true that where the venture is a small one, the shareholders few, and the transac- tion resembles a partnership under corporate guise, the subscrib- ers may well believe that the promoters are making no profit and seeking no compensation for their services.

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