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Table of Contents 1 Definition of a Corporation 2 Organization and Capitalization of Corporations
04 Tax Treatment of Corporate IssuerTransferee S212
33 other sections not shown
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3d Cir 5th Cir acquired adjustment AFTR2d agreement allocated amount apply assets bad debt bank bankruptcy basis capital common stock computing consolidated group consolidated return constructive dividends contract Corp corporate characteristics corporation's stock costs creditors distribution dividends earnings tax employees Estate exchange expenses filed final Regulations Fisk's shareholders foreign tax credit funds Held holding company incurred indebtedness interest inventory investment IRS argued IRS disallowed IRS ruled IRS's LIFO limited liability company liquidation loan million ownership paid paragraphs f parent corporation partners payments percent preferred stock Priv Proposed Regulations purchase qualified received redemption references to Supplement reorganization responsible person revenue procedure revenue ruling RIA TC Memo Section 83 shareholder's shares sold Supplement are preceded Tax Court tax purposes Taxpayer argued taxpayer claimed transaction transfer USTC H windfall profits tax withholding taxes