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Note:

Securities Regulation -- Shares of a State-Subsidized Non-Profit Cooperative Housing Corporation Are Securities Under Federal Securities Laws, Forman v. Community Services, Inc. (2d Cir. 1974)., Texas L. Rev. (1975).

In this note, the author argues that “the court’s literalist reading of ‘stock’ has a superficial plausibility, but it is weakly grounded in authority and reason.” In addition, it argues that the Second Circuits use of the Howey test was flawed because counting rent savings as profits is not a fair reading of the statutes and legislative history.