...or for Investment. (2) STOCK FOR STOCK OF SAME CORPORATION. — No gain or loss shall be recognized If common stock In a corporation Is exchanged solely...of the plan of reorganization, exchanged solely for atock or securities In such corporation or in erty. The record clearly shows that petitioner received...

...1036. STOCK FOR STOCK OF SAME CORPORATION. (a) GENERAL RULE. — No gain or loss shall be recognized U.S. Govt. Print. Off." " United States( s(d)...any person who" USES DEFINED AS SALES. — If a pr (b) CROSS REFERENCES. — (1) For rules relating to recognition of gain or loss where an exchange is...

...AND SECURITIES IN CERTAIN REORGANIZATIONS, (a) GENERAL Run. — (1) In GENERAL. — No gain or IOM shall be recognized If stock or securities in a corporation a party to a reorganization are, In pursuance of tbe plan of reorganisation, exchanged solely for stock or securities In such corporation or In another...

...which section 1036 applies. Section 1036 of the Code states that no gain or loss shall be recognized if common stock in a corporation is exchanged solely...solely for preferred stock in the same corporation. In Rev. Rul. 57-451, 1957-2 CB 295, it is noted that for purposes of section 1036 of the Code, a "simultaneous...

...general rule stated in section 1002 of the Code and provides that no gain or loss shall be recognized if common stock in a corporation is exchanged solely...solely for preferred stock in the same corporation. Section 1.1036-1 (a) of the Income Tax Regulations provides, in part, that section 1036 of the Code...

...the Code apply to the exchanges by A and B. Section 354(a)(l) of the Code provides, in part, that no gain or loss shall be recognized if stock or securities...corporation a party to a reorganization are, in pursuance of a plan of reorganization, exchanged solely for stock or securities in such corporation. Where the exchange...

...loss sustained. Under section 354(a)(l) and (a) (2) of the Code no gain or loss shall be recognized if securities in a corporation a party to a reorganization...of the plan of reorganization, exchanged solely for securities in such corporation or in another corporation a party to the reorganization if the principal...

...a favorable ruling was not required. Section 1036 provides that no gain or loss shall be recognized if common stock in a corporation is exchanged solely...solely for preferred stock in the same corporation. Section 1036 is not limited to an exchange between two individual stockholders; it includes a transaction...

...1036. Stock for stock of same corporation — (a) General rule. No gain or loss snail be recognized If common stock In a corporation Is exchanged solely...solely for preferred stock In the same corporation. (b) Cross references. (1) For rules relating to recognition of gain or loss wliere an exchange Is not...

...reorganizations qualifying as such under section 368(a)(l). Specifically, under section 354(a)(l)— No gain or loss shall be recognized if stock or securities...of the plan of reorganization, exchanged solely for the stock or securities in such corporation or in another corporation a party to the reorganization....