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THE INDIVIDUAL INCOME TAX CORPORATE DISTRIBUTIONS
b Constructive Dividends
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acquiring corporation acquisition agreement amount apply assets basis Burr Oaks capital gain carryover cash cent certiorari Circuit Judge Commissioner of Internal common stock Company complete liquidation Congress contends corporation's debt decision deduction determined distribution earnings and profits effect essentially equivalent fact fair market value Federal Income foreign corporation gain or loss held Helvering holders interest Internal Revenue Code issued Krispy Kreme liability merger notes operating loss ordinary income outstanding stock ownership paid parent parent's stock party payment percent petitioner petitioner's plan of reorganization poration preferred stock prior promissory notes purchase pursuant question real estate realized received recognized redemption respondent result Revenue Act Revenue Ruling section 351 shareholders shares sole statute statutory Stauffer stock dividend stock or securities stockholders subsidiary substantial supra tax consequences Tax Court taxation taxpayer tion trade or business transaction transfer transferor corporation treasury stock voting stock