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Table of Cases
Commissioner 42 T C 114 Tax
Table of Treasury Regulations
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acquiring corporation acquisition adjusted basis allocation alternative minimum tax amount apply assets attribution boot business purpose capital account capital gains cash Code Commissioner common stock Congress contributed property contribution controlled corporation corporate level corporation's debt deduction determined distributing corporation dividend doctrine earnings and profits economic effect election entity equity exchange facts fair market value gain or loss held holding individual investment issued liability limited liquidation loan loss corporation merger nonrecognition obligation ordinary income ownership change partner partnership interest payment Peracchi petitioner preferred stock prior provides purchase pursuant qualify receipt received recognized redeemed redemption regulations reorganization requirement result revenue procedure Safe Harbor Section 351 securities shareholder's shareholders shares statute statutory Subchapter subsidiary substantially target corporation tax avoidance tax consequences Tax Court tax purposes tax-free taxable income taxation taxpayer Teorco tion transfer transferor treated treatment voting stock