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DISTRIBUTIONS TO SHAREHOLDERS
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2d Cir 301 distribution 5th Cir acquiring corporation adopted allocated amount apply assets Bardahl basis Bittker Blackacre boot Bull capital gain capital loss cash cert Circuit Commissioner common stock constitute Corp corporation's stock Court held Cum.Bull decision deduction deemed depreciation determined distributing corporation earnings and profits election excess exchange fair market value gain or loss gain recognized gross income holder income tax liabilities liquidating distribution nonrecognition operating loss ordinary income outstanding stock ownership paid parent corporation partner passive income payment personal holding company PHC income poration preferred stock prior provision purchase pursuant qualify realized received recognize gain recognize income redeemed redemption regulations reorganization requirement Rev.Rul S.Ct section 306 stock shareholder statutory stock and securities stock dividend Subchapter S corporation subsidiary corporation supra tax avoidance tax consequences Tax Court taxable income taxpayer tion transaction transfer transferor Treas.Reg treated treatment trust United voting stock