BUFFINGTON, Circuit Judge.
In this income tax case it appears that Bell owned 10,386 shares of stock in Lederle Antitoxin Laboratories (hereafter called Antitoxin), having a cost basis of $90,384.85. A reorganization agreement was drawn up between Antitoxin and American Cyanamid Company (hereafter called Cyanamid) whereby Antitoxin would convey all of its assets to Cyanamid or its nominee for 64,500 shares of Cyanamid class B common and 75,000 nonvoting preferred...
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