Winston Bros. Co. v. Commissioner

In 1928 petitioner exchanged 1,116 shares of its preferred stock and 1,803 shares of its common stock for all the business and assets of another corporation, pursuant to a plan of reorganization. At the time of exchange, petitioner owned approximately 68 percent of the common stock of the transferor corporation, and immediately thereafter the latter corporation distributed among its stockholders in final liquidation the shares of petitioner's common stock acquired in exchange for its original assets. Petitioner received back 1,232 shares of its own common stock as a liquidating dividend, and…