In several other bond/debt modification cases, the courts have held that the refunding bonds were not different in kind from the original bond, and hence no realization event occurred. Mutual Loan and Savings Co. v. Commissioner, 184 F.2d 161, 165 (5th Cir. 1950); C.M. Hall Lamp Co. v. United States, 97 F. Supp. 481, 486-87 (E.D.Mich. 1951); West Missouri Power Co. v. Commissioner, 18 T.C. 105, 111 (1952). SASA argues that these debt modification cases are not good authority for the material difference requirement, because these cases involved "constructive exchanges" rather than genuine exchanges.

* * * See also City Bank Farmers Trust Co. v. Hoey, 52 F.Supp. 665; West Missouri Power Co., 18 T.C. 105; Hort v. Commissioner, 313 U.S. 28; and Charles E. McCartney, 12 T.C. 320. What was said in Motor Products Corporation, supra, can be said here.