United States Board of Tax Appeals April 7, 1942, Docket No. 103431 (Menefee v. Commissioner)

*867OPINION.

SternhageN :

The petitioner contends that as to her no gain may be recognized in the receipt of the West Coast shares from the La Dee *868corporation, Eevenue Act of 1936, sec. 112 (b) (3).1 The respondent treats section 112 (b) (3) as irrelevant because petitioner’s shares in La Dee were not “exchanged * * * in pursuance of a plan of reorganization.