Georgia Savings Bank & Trust Co. v. Commissioner

*1161OPINION.

Trammell:

The issue here is whether the petitioners exchanged their stock in the Excelsior Laundry Co. for 5,000 shares of preferred and 12,500 shares of common stock in Atlanta Laundries, Inc., plus $200,000 cash, or whether they exchanged their stock in the old corporation for stock only in the new corporation. The transaction occurred in 1928, under the circumstances set out in our findings of fact.

The respondent has determined, and the petitioners concede, that the transaction constituted a reorganization within the meaning of that term as used in section 112 (i) (1) of the Revenue…