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Table of Treasury Regulations
Table of Miscellaneous Rulings Iv
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80 percent accumulated earnings acquiring corporation acquisition agreement allocation amount apply assets assignment of income Bittker boot capital gain cash Commissioner common stock complete liquidation Congress corporate tax corporation's debt deduction determining earnings and profits election entity exchange fact fair market value Foglesong gain or loss held Helvering interest Internal Revenue Code Internal Revenue Service investment issue liability limited partners limited partnership ment merger nonrecognition operating ordinary income ownership paid payment petitioners preferred stock prior Professor of Law provides purchase pursuant qualify received redeemed redemption regulations reorganization result Rev.Rul S.Ct Section 351 section 482 sell Service Sess shareholder's shareholders shares solely statute statutory stock or securities stockholders Subchapter subsidiary substantially supra target target corporation tax avoidance tax consequences Tax Court tax-free taxable income Taxation taxpayer tion trade or business transaction transfer transferor treated treatment trust ULPA United voting stock