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B Nonrecognition of Shareholder Gain
23 Foreign Personal Holding Company
82 other sections not shown
2d Cir 351 exchange 50 percent 5th Cir acquired adjusted basis affd allocated amount apply assets Bardahl bonds capital gain capital loss cash cert Code computing constitute constructive dividend Corp corporation's current earnings debt deduction dend denied distribution divi dividends received earnings and profits election enacted equity excess expenses fair market value gain or loss gross income held holder income tax infra H interest Internal Revenue Service investment issue discount liability loan obligations operating loss ordinarily ordinary income organization P-H Memo TC paid partial liquidation partnership payment personal holding company poration preferred stock provides purchase purpose qualify rata recognized redemption Regs regulations reorganization rules Service shareholder's shareholders shares status statutory stock dividend stock or securities stockholders Subchapter S corporation subsidiary supra H supra note tax-free taxable income taxation taxpayer tion transaction transfer transferor treated treatment trust undistributed