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UNITED STATES v. MURDOCK

No. 13517.

263 F.2d 146 (1959)

UNITED STATES of America, Appellant, v. John E. MURDOCK and Wife, Vera S. Murdock, Appellees.

United States Court of Appeals Sixth Circuit.

January 5, 1959.

Attorney(s) appearing for the Case

Charles K. Rice, Lee A. Jackson, Grant W. Wiprud, Washington, D. C., Millsaps Fitzhugh and Edward N. Vaden, Memphis, Tenn., for appellant.

Lowell W. Taylor, Memphis, Tenn., for appellees.

Before ALLEN, Chief Judge, SIMONS, Circuit Judge, and KENT, District Judge.

PER CURIAM.

The General Insurance Agency of Tennessee, a corporation, distributed to its stockholders, including taxpayers here, certain shares of stock of the Universal Security Insurance Company and Apex Realty Company, which had been purchased for cash by General Insurance Agency.

The sole question on this appeal is whether such distribution of stock constituted a re-organization within the intent of Section 112(g) (1) (D) of the Internal Revenue Code of...

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