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Chapter 1Basic Issues Under Primitive Statutes
Under the Revenue Act of September 8 1916
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accumulated earnings acquiring corporation acquisition agreement amount apply assets basis bonds business purpose capital gain cash Circuit Judge Commissioner common stock complete liquidation Cong Congress corporation's cost debt decision deduction determined distribution earnings and profits effect essentially equivalent exchange fact fair market value gain or loss held Helvering holders holding income tax interest Internal Revenue Code investment issue liabilities loss carryover merger nonrecognition Old Nassau operating loss opinion ordinary income ownership paid payment percent petitioner petitioner's Phellis plan of reorganization poration preferred stock prior provisions purchase pursuant question realized reason received recognized redeemed redemption regulations respondent result Revenue Act REVENUE RULING section 337 securities sell shareholders shares sold solely statute statutory stock dividend stockholders subsidiary substantial supra surplus tax avoidance Tax Court taxation taxpayer Teragram tion transaction transfer transferor treasury stock treated treatment United voting stock