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B Nonrecognition of Shareholder Gain
89 other sections not shown
2d Cir 351 exchange 50 percent 5th Cir accumulated earnings acquired adjusted basis aff'd allocated amount apply assets Bardahl beneﬁciary beneﬁt bonds capital gain capital loss cash cert classiﬁcation Code computing constitute constructive dividend Corp corporation’s Court debt deduction deﬁned deﬁnition dend denied distribution divi dividends received eamings earnings and proﬁts election equity excess expenses fair market value ﬁrst gain or loss gross income held holder income tax infra 11 infra Ch interest investment issue discount liability loan obligations operating loss ordinarily ordinary income organization P-H Memo TC partnership payment personal holding company poration preferred stock provides purpose qualiﬁed rata redemption reﬂect Regs regulations reorganization Revenue rules Service shareholder’s shareholders shares status statutory stock dividend stock or securities stockholders Subchapter S corporation subsidiary supra 11 supra note tax-free taxable income taxation taxpayer tion transaction transfer transferor treated treatment trust