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Taxation of Corporations and Shareholders
The Capital Structure of the Corporation
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15 percent acquiring corporation acquiring corporation's allocated apply brand X business purpose requirement capital gains capital losses carryover paragraph cash citation to Treas Clinpath stock COBE Colonial Colonial's Commissioner consolidated group continuity of business controlled corporation corporate business purpose Corporation stock covenant deduction disregarded entity distributing corporation earnings and profits election evidence of device exchange fair market value gain or loss Income Tax Regs individual taxpayers otherwise insert interest Internal Revenue Service liquidation loan municipal bond nonrecognition operating loss ordinary income parent party percent for individual petitioner plan of reorganization preferred stock product liability provides pursuant QSSS qualified stock purchase recognize gain regulations replace the citation result Revenue Ruling Ridge satisfied second full paragraph section 355 shareholder's shareholders shares spinoff statutory merger substantial Sunbelt target corporation Tax Court tax-exempt bonds taxpayers otherwise taxable Temp trade or business treated voting stock X automobile