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TAXATION OF C CORPORATIONS
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50 percent acquiring corporation acquisition amount apply assets basis Bollinger boot borrowing capital gain cash payment chicken ranch Code Commissioner common stock Cong Congress controlled corporation corporate tax corporate-level corporation's Court of Appeals debt and equity device disallowance distributing corporation doctrine earnings and profits effect Esmark ESOPs example exchange fair market value Federal income taxes financing Finks full paragraph gain or loss greenmail interest deductions Internal Revenue Internal Revenue Code investment investors issues leveraged buyout limitation liquidation ment merger million operating ordinary income ordinary loss ownership partnership principal prior proposals provides qualified recognize gain recognized built-in gain reduced reorganization result Rev.Rul RJR Nabisco rule S.Ct Section 355 Sess shareholder's shareholders shell corporation statute stock or securities stock repurchase stock surrender subsidiary supra TAMRA target corporation tax avoidance tax consequences Tax Court tax treatment tax-free taxable income taxpayer tion trade or business transaction transfer treated