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Developing a Strategy for a Failing Company
103 Avoiding Liability for Employment Taxes
104 Potential Creditor Liability for Debtors Withholding Taxes
58 other sections not shown
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2d Sess 9th Cir accrued acquired acquisition adjusted principal amount allocation alternative minimum tax amendment apply assets attributable automatic stay bank Bankr Bankruptcy Code section bankruptcy court Bankruptcy Tax Act basis built-in gain built-in loss carryovers cash Chapter 11 plan COD income Commissioner consolidated return Corp creditors debt cancellation debtor debtor corporation deduction determining discharge discussed effective election equity example exchange failing company filed fund held holder indebtedness interest involved IRS Letter Ruling issuance liquidation loss company loss corporation NOLs nonrecourse debt occurring old debt option ownership change parent payment percent shareholder period postpetition preferred stock prepetition prior proceeding proof of claim proposed regulation provides purchase purposes pursuant recapitalization refund reorganization sovereign immunity stock issued stock-for-debt exception subsidiary supra note target corporation Tax Court taxable taxpayer testing date tion transaction transfer treated trust United unpaid unsecured unsecured creditors