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PART IINTRODUCTION AND REVIEW OF BASIC CONCEPTS
Treatment of Share
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accounts receivable accumulated earnings acquired adjusted basis agreement allocation amount apply assets capital gains cash Commissioner common stock computing contract contributed property contribution controlled foreign corporation corporation's debt deduction depreciation determining distributive share dividend dollars earnings and profits election excess fact fair market value Federal income tax gain or loss gross income held Internal Revenue Code Internal Revenue Service investment issue limited partners limited partnership loan meaning of section mortgage nonrecognition notes ordinary income ownership paid partnership interest payment personal holding company petitioner preferred stock prior provides purchase pursuant qualify question realized receipt recognized redemption regulations respect result rule sale or exchange section 351 securities sell Service shareholder's shareholders stockholders subchapter S corporation subsidiary substantial supra Sec tax avoidance tax benefit Tax Court tax liability tax purposes taxable income taxation taxpayer tion trade or business transaction transfer transferor treated treatment United