¶1dissenting: In my opinion, the facts in this case bring it squarely within the reorganization provisions of the statute as interpreted by the Supreme Court in the Pinellas case and by the court of appeals in the Cortland Specialty case, cited in the above case. The reorganization provisions do not require that one corporation be dissolved. The reorganization as defined in the statute is not limited to a technical merger or reorganization, but is made broader by the parenthetical clause. There was, in my opinion, the continuing interest which the above decisions referred to as being necessary.
28 B.T.A. 1056
Watts v. Commissioner
United States Board of Tax Appeals
Decided August 11, 1933
United States Board of Tax Appeals · decided 1933-08-11
The transaction herein detailed not resulting in a reorganization, gain or loss is to be recognized to petitioners.
Cited by 15 later decisions — most recently May 1952
2 federal appellate ·
Good law ✅— No negative treatment on recordhow we know
Decided 1933-08-11
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