ALBERT V. BRYAN, District Judge.
The Tax Court rejected the petitioner's contention that the receipt by him in 1953 from his solely owned corporation of the entire capital stock of a subsidiary corporation was not taxable, as income, because it was distributed in a plan of corporate reorganization — a "spin-off" to the tax versant — in which, by section 112(b) (11), Internal Revenue Code of 1939
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