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Table of Cases
Table of Revenue Rulings and Procedures
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50 percent accounts receivable accumulated earnings acquiring corporation acquisition adjusted basis agreement allocated apply assets boot business purpose capital gain cash classes of stock Commissioner common stock consolidated return continuity of interest contribution controlled corporation corporation's debt instrument deduction determining distributing corporation doctrine earnings and profits equity fair market value federal income tax gain or loss held Helvering holder Internal Revenue Code Internal Revenue Service liquidation meaning of section merger operating ordinary income original issue discount ownership paid partnership payment personal holding company petitioner preferred stock principal amount proposed regulations provides purchase pursuant qualify recapitalization recognized redeemed requirement result Rev.Rul REVENUE RULING S.Ct S's stock sale or exchange section 306 stock section 351 sell shareholder's shareholders shares sole proprietorship solely stock dividend stock or securities stock received stockholders subsidiary substantially target target corporation tax avoidance Tax Court tax-free taxable income taxation taxpayer tion transfer transferor treated voting stock