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The Corporation Income Tax
Gain or Loss on the Disposition of Property
46 other sections not shown
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acquiring corporation acquisition Aetna agreement amount apply assets attribution rules basis Burr Oaks business purpose capital gains cash Commissioner common stock Company Congress contends corporate tax corporation's debt decision deduction determined distribution earnings and profits effect Elkind equity essentially equivalent exchange fact fair market value gain or loss held Helvering holders holding Internal Revenue Code Internal Revenue Service investment involved issued liabilities loan merger nonrecognition notes ordinary income ownership paid partnership payment percent petitioner petitioner's plaintiff poration preferred stock prior provides purchase pursuant qualify realized receipt received recognized redeemed redemption regulations reorganization requirement result REVENUE RULING Ritz section 351 sell shareholder's shareholders shares sole statute statutory stock dividend stockholders subsidiary substantially supra target corporation tax avoidance tax consequences Tax Court tax-free taxable income taxation taxpayer trade or business transaction transfer transferor Treas treated voting stock