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Bankruptcy Versus Nonbankruptcy
Treatment of Creditors in Nonbankruptcy Debt
Deduction and Accrual of Interest
47 other sections not shown
9th Cir acquired acquisition aff'd amended amount apply assessment automatic stay bank Bankr Bankruptcy Code section bankruptcy court basis built-in loss cancellation carryback carryovers cash Chapter 11 plan Circuit COD income Commissioner Cong consolidated return Corp creditors debtor deduction determination discharge discussed effect election Eleventh Amendment equity exchange failing company federal filed fund held income tax interest involved IRS Letter Ruling IRS Manual IRS's issuance issued LEXIS liquidating trust loss company loss corporation NOLs old Code option ownership change payment penalty percent shareholder period postpetition preferred stock prepetition taxes prior priority proceeding proof of claim proposed regulations provides purchase purposes pursuant recapitalization refund reorganization setoff sovereign immunity SRLY statute of limitations stock-for-debt exception subsidiary supra note target corporation tax claim Tax Court tax liability taxable taxpayer tion transaction transfer treated two-company United unpaid unsecured withholding taxes