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01 Organizations Incorporated Under State Law
Table of Contents vii
Carryover and Survival of Corporate Tax Attributes
41 other sections not shown
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50 percent 5th Cir accounts receivable acquiring corporation acquisition adjusted basis advances affiliated group Affirmed AFTR2d agreement allocated amount apply assets bad debt bank business purpose capital contributions capital gain carryback carryover cash common stock consolidated return constructive dividend Corp corporation's stock debentures deduction distribution earnings and profits equity exchange expenses fair market value filed income tax indebtedness interest investment IRS argued IRS contended IRS determined IRS disallowed IRS held IRS ruled issued lease liabilities loans merger notes operating loss option ordinary income ownership P-H Memo paid parent corporation partnership payments personal holding company poration preferred stock prior purchase pursuant qualified real estate redeemed redemption Regulation result Section 306 stock Section 351 Section 482 shareholders shares sold sole proprietorship sole stockholder target corporation tax avoidance Tax Court held tax-free Taxpayer claimed Taxpayer corporation transaction transferor transferred trust USTC 11