June M. Carlberg, by Vida M. Frick, Guardian v. United States

BLACKMUN, Circuit Judge.

This case, genuine but admittedly test litigation, involves the federal income tax consequences of one aspect of the statutory merger, effected in November 1956, of The Long-Bell Lumber Corporation, a Maryland corporation, and The Long-Bell Lumber Company, a Missouri corporation, into International Paper Company, a New York corporation, the survivor. These corporate entities will be referred to as “Maryland”, “Missouri”, and “International”, respectively. 1

The statutes in question are § 368(a) (1) (A), § 354(a) and § 356(a) of the Internal Revenue Code of 1954, 26…