Mutual Loan & Savings Co. Of West Palm Beach, Fla. v. Commissioner of Internal Revenue

RUSSELL, Circuit Judge.

The question presented by this petition for review of a determination of the Tax Court is whether transactions, by which the taxpayer, as a party to a petition by two Florida municipal corporations for relief under Chapter IX of the Bankruptcy Act, 1 and pursuant to a plan of composition in such proceeding, surrendered defaulted municipal bonds and detached interest coupons for refunding bonds of the municipalities, constituted the "sale or exchange of property” and the realization of taxable gain within the terms of sections 111, 112(a) of the Internal Revenue Code, 26…