...shall be recognized, except as hereinafter provided In this section. "(b) Exchanges solely In kind — "(5) Transfer to corporation controlled by transferor....In the case of an exchange by two or more persons I Ms paragraph shall apply only If the amount of the stock and securities received by each is substantially...

...non-recognition of gain or loss under section 112 (b) (5) of the Revenue Act of 1928. This section provides : No gain or loss shall be recognized if property is transferred...exchange for stock or securities in such corporation, * * * [Emphasis supplied.] In order for plaintiffs to come within this section they must show that...

...corporation is exchanged solely for preferred stock in the same corporation.1 (3) No gain or loss is recognized if property is transferred to a corporation...the exchange such person or persons are in control (that is, have the ownership of at least 80 % of the voting 1 See Revenue Act of 1924, Section 208....

...case comes under Revenue Act of 1926, §203(b)4, US COMP. STAT. (Supp. Feb. 1926) §6336-l/3bb: "No gain or loss shall be recognized if property is transferred...solely in exchange for stock or securities in such a corporation, and immediately after the exchange such person or persons are in control of the corporation....

...Exchange of property for securities of a controlled corporation. — LAW. Section 203 (b) .... (4) No gain or loss shall be recognized if property is transferred...person or persons are in control of the corporation; *5 but in the case of an exchange by two or more persons this paragraph shall apply only if the amount...

...type of transaction referred to in section 203 (b) (4) of the Revenue Act of 1924 is that in which property is transferred to a corporation by one or...person or persons are in control of the corporation. Section 202 (c) of the Revenue Act of 1921 provides: For the purposes of this title, on an exchange...

...BTA 1273 ; Katherine A. Spalding, 7 BTA 588 ; BF Saul, 4 BTA 639 : EH Nielsen Co., 26 BTA 223. 1 No gain or loss shall be recognized If property Is transferred...exchange for stock or securities In such corporation, and Imnn^diately after the exchange such person or persons are in control of the corporation ; bat in the...

...section 202, shall be recognized, except as hereinafter provided in this section. ******* (b)(4) No gain or loss shall be recognized if property is transferred...corporation ; but in the case of an exchange by .two nr more persons this paragraph shall apply only if the amount of the stock and securities received...

...existed in the earlier law.8 1 RECOGNITION OF GAIN OR LOSS FROM SALES AND EXCHANGES. SBC. 203. (b) (4) No gain or loss shall be recognized if property Is transferred...Immediately after the exchange such person or persons nre in control of the corporation ; but in the case of an exchange by two or more persons this paragraph...

...TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized If property la transferred to a corporation by one or more persons...Immediately after the exchange such person or persons arc In control of the corporation ; but In the case of an exchange hy two or more persons this paragraph...