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PAULSEN v. COMMISSIONER

No. 83-832.

469 U.S. 131 (1985)

PAULSEN ET UX. v. COMMISSIONER OF INTERNAL REVENUE

Supreme Court of United States.

Decided January 8, 1985.

Attorney(s) appearing for the Case

William R. Nicholas argued the cause for petitioners. With him on the briefs was Karen S. Bryan.

Albert G. Lauber, Jr., argued the cause for respondent. With him on the brief were Solicitor General Lee, Acting Assistant Attorney General Olsen, and Ernest J. Brown.*

JUSTICE REHNQUIST delivered the opinion of the Court.

Commerce Savings and Loan Association of Tacoma, Wash., merged into Citizens Federal Savings and Loan Association of Seattle in July 1976. Petitioners Harold and Marie Paulsen sought to treat their exchange of stock in Commerce for an interest in Citizens as a tax-free reorganization under 26 U. S. C. §§ 354(a)(1) and 368(a)(1)(A). The Court of Appeals for the Ninth Circuit, disagreeing with the Court...

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