Miller v. Commissioner

*1067OPINION.

Marquette:

The petitioners assert that they are not taxable on the gain arising from the exchange of part of their stock in the News Co. for a part of the stock of Publications, Inc. They con*1068tend that there was a reorganization within the meaning of subsection (i) (1) of section 112 of the Eevenue Act of 1928, with the result that subsections (b) (3) and (c) (1) of the same section apply.

Subsection (i) (1) provides:(1) The term “reorganization” means (A) a merger or consolidation (including the acquisition by one corporation of at least a majority of the voting stock and at least a…