The United States Supreme Court in Turnbow v. Commissioner may have interpreted the Internal Revenue Code to preclude the receipt of "boot" in a non-taxable, stock for stock reorganization. Although the Court was interpreting the application of Section 112 of the 1939 Code, the decision may be decisive in the interpretation of the parallel sections in the 1954 Code.
F. R. DeBruyn,
Turnbow v. Commissioner—Rejection of the "Boot" Exception to a Type B Reorganization?,
Wash. L. & Rev.
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