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HEVERLY v. C. I. R.

No. 79-1985. No. 79-2192.

621 F.2d 1227 (1980)

Arden S. HEVERLY and Sophia S. Heverly v. COMMISSIONER OF INTERNAL REVENUE. (Tax Court No. 4953-74) Edna L. BOYER, Deceased, by John H. Bozic, Jr., Executor of the Estate of Edna L. Boyer v. COMMISSIONER OF INTERNAL REVENUE. (Tax Court No. 6153-74) Katherine D. HARVEY v. COMMISSIONER OF INTERNAL REVENUE. (Tax Court No. 6187-74) John J. DeFRAINE and Agnes C. DeFraine v. COMMISSIONER OF INTERNAL REVENUE. (Tax Court No. 8602-74) Appeal of COMMISSIONER OF INTERNAL REVENUE. John Lewis PIERSON v. UNITED STATES of America, Appellant.

United States Court of Appeals, Third Circuit.

Decided March 25, 1980.

Attorney(s) appearing for the Case

Ernest J. Brown (argued), M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Tax Div., Dept. of Justice, Washington, D. C., for appellants; James W. Garvin, Jr., U. S. Atty., Wilmington, Del., of counsel.

John H. Schafer (argued), Newman T. Halvorson, Jr., Charles Lister, Covington & Burling, Washington, D. C., Stephen D. Gardner (argued), James S. Eustice, Kronish, Lieb, Shainswit, Weiner & Hellman, New York City, for appellees; Robert A. Kagan, Edwin A. Kilburn, New York City, of counsel.

Before ALDISERT, WEIS and HIGGINBOTHAM, Circuit Judges.

OPINION OF THE COURT

ALDISERT, Circuit Judge.

The major issue presented by these consolidated appeals from the United States Tax Court and the United States District Court for the District of Delaware is whether the use of consideration other than voting stock is allowable in a tax deferred stock for stock reorganization as defined in § 368(a)(1)(B) of the Internal Revenue Code, 26 U.S.C. § 368(a)(1)(B). In the vernacular, the question is whether...

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