Federal Income Taxation of Corporate Enterprise
"This is a comprehensive casebook on federal income taxation of corporations, focusing almost entirely on issues arising under Subchapter C of the Internal Revenue Code. It is aimed at students who have already completed a basic course in federal income taxation, and so have an understanding of basic tax concepts. In addition to helping students understand the statutes and their admninistrative and judicial overlays, the book encourages them to evaluate the law and the various proposals for changing it."--Publisher's website.
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The Corporations IncomeIts Special Aspects
TA B L E O F C A S E
Gloucester Ice Cold Storage Co v Commis 1992
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acquiring corporation acquisition Aetna agreement amount apply assets attribution rules basis Burr Oaks business purpose capital gains capital stock cash Circuit Judge CLIC Commissioner common stock Company Congress Conoco constituted Corp corporate income corporate tax corporation's creditors debentures debt decision deduction determined earnings and profits effect equity essentially equivalent exchange fact fair market value gain or loss Helvering income tax interest Internal Revenue Code Internal Revenue Service investment issue liabilities loan merger nonrecognition notes ordinary income outstanding ownership paid payment percent petitioner petitioner's plaintiff preferred stock prior pursuant qualify question realized received recognized redeemed redemption regulations reorganization requirement result section 382 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 tion transaction transfer transferor treated treatment U.S. Steel voting stock