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Accelerated Depreciation See Depreciation Methods of Reallocation 75
Accumulated Earnings Tax 3 Procedure 82
Acquiring Corporations CarryOver of Tax Assumption of Liabilities See Liabilities Assumption
18 other sections not shown
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5th Cir accumulated earnings tax acquired advances affiliated Affirmed AFTR2d allocated amount assets bad debt deduction bank Bardahl basis bona fide bonds bonuses business needs capital gain cash collapsible consolidated return constructive dividend controlled Corp corporation's court found debentures dends denied distribution district court divi duction earnings and profits employees equity excess fact fair market value filed funds holders indebtedness interest investment IRS contended IRS determined IRS disallowed issued jury lease liability loans loss carry-over ment ness notes officers operating loss ordinary income P-H Memo parent partnership payer payments percent poration preferred stock president prior promissory notes purchase purpose pursuant real estate received repayment Section 337 Section 482 sold sole stockholder sonable stockholder's subsidiary substantial Supp tax avoidance Tax Court held taxable taxpay Taxpayer claimed Taxpayer corporation Taxpayer failed tion transaction transferred unreasonable USTC