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COMMISSIONER OF INTERNAL REVENUE v. EDMONDS' ESTATE

No. 9361.

165 F.2d 715 (1948)

COMMISSIONER OF INTERNAL REVENUE v. EDMONDS' ESTATE et al.

Circuit Court of Appeals, Third Circuit.

Decided January 27, 1948.

Attorney(s) appearing for the Case

Helen Goodner, of Washington, D. C. (Sewall Key, Acting Asst. Atty. Gen., and Lee A. Jackson, Sp. Asst. to Atty. Gen., on the brief), for petitioner.

Richard V. Zug, of Philadelphia, Pa. (J. Warren Brock and Edmonds, Obermayer & Rebmann, all of Philadelphia, Pa., on the brief), for respondents.

Before MARIS, O'CONNELL, and KALODNER, Circuit Judges.

O'CONNELL, Circuit Judge.

The Commissioner of Internal Revenue appeals herein from a Tax Court decision holding that, in 1935, an exchange of old debentures for new collateral trust income bonds of the Portland Electric Power Company (hereinafter called Portland) was pursuant to a reorganization within the meaning of Sections 112(b) (3), 112(g) (1) (D), and 113(a) (6) of the Revenue Act of 1934, c. 277, 48 Stat. 680, 26 U.S.C.A. Int.Rev. Acts 1924 to date, pages 692...

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