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Chapter Two The Shareholder Income Tax
Chapter Three Incorporation of Assets
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100th Congress accumulated earnings acquiring corporation acquisition affiliated group agreement amount apply ARCNs assets AT&T attribution rules basis Blackard capital gains casebook cash Chicago Bank Circuit Coca-Cola Code Commissioner common stock Congress consolidated return corporation's Crane debt deduction depreciation determining earnings and profits economic election equity exchange fair market value Federal gain or loss Goldfine Haberstroh held income tax interest Internal Revenue Internal Revenue Code issue liability liquidation loan McDonald's member banks merger Metzger Dairies mortgage nonrecourse nonrecourse debt nonrecourse loan Note obligation ordinary income ownership paid partner partnership percent petitioners plaintiff poration preferred stock production payment provides purchase purpose pursuant qualified received redeemed redemption regulations reorganization repeal requirement restricted stock shareholder shareholder's statutory stock dividends stockholders Subchapter subsidiary substantial target corporation tax avoidance Tax Court Tax Reform Act tax-free Taxation taxpayer TEFRA transaction transferred treated Trust