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History and Future of Subchapter
9 No Agreement Requiring Cooperation Under Section 13620 176
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2d Sess 97th Cong accumulated adjustments account accumulated earnings adopted allocated allow amount apply assets Bittker capital gain class of stock Congress consent corporation's taxable debt deduction distributions dividends earnings and profits elect under Section elect under subchapter electing small business example filed former IRC former Section former Treas grantor trust gross receipts held HR Rep income beneficiary infra H interest investment credit LIFO limit limited liability company ordinary income P-H TC Memo partnership pass-through passive activity passive investment income payments percent poration prior law Proc provides qualified subchapter recapture reduce refers to IRC Regarding regulations result Revision Act RIA TC Memo Service share shareholder shareholder's small business corporation small business trust status stock basis Subchapter S Revision subchapter S subsidiary subchapter S trust tax-free Tax'n taxable years starting taxpayer TC Memo H termination tion transfer treated voting trust