sentences:  He started with "Eisner v. Macomber" (1920), which dealt with exchange of stock in corporations.In several cases after "Eisner", the court held that an exchange of stock which occurred when a corporation reorganized in another state was a realization, because corporations have different rights and power in different states.Marshall reasoned that properties materially differ for tax purposes when their respective possessors enjoy different legal entitlements from each.