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Table of Cases
Table of Treasury Regulations
Table of Proposed Treasury Regulations
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50 percent acquiring corporation acquisition adjusted basis allocation alternative minimum tax amount apply assets attributable boot C-type capital account capital gains carryover cash Commissioner common stock contributed property contribution controlled corporation corporation's debt deduction depreciation determined distributing corporation distributive share dividend earnings and profits economic effect election entity equity exchange fact fair market value gain or loss held individual investment issue liabilities liquidation loan loss corporation meaning of section merger nonrecognition nonrecourse nonrecourse debt obligation ordinary income outstanding ownership change partner partnership income partnership interest payment petitioner petitioner's preferred stock prior provides purchase pursuant qualify received recognized redemption regulations reorganization requirement result REVENUE RULING Section 351 securities shareholder's shareholders statutory Subchapter subsidiary substantially target corporation tax avoidance tax consequences Tax Court tax free tax purposes taxable income taxation taxpayer Teorco tion transaction transfer transferor treated treatment voting stock