Roelker v. Commissioner

1. A trust company, in which petitioner held two blocks of stock acquired at different times, reduced its capital stock from 600,000 shares to 352,000 shares in connection with a plan of reorganization. Petitioner exchanged her certificates for cash and new certificates based upon the reduced capital. Held, that the old stock was exchanged for stock and money in pursuance of a plan of reorganization, under section 112(c)(1), Revenue Act of 1928. 2. Prior to the taxable year the corporation changed its name and was transformed from a bank into a trust company under the laws of New York. Held,…