Federal taxation of S corporations and shareholders
Lorence L. Bravenec, American Law Institute-American Bar Association Committee on Continuing Professional Education
American Law Institute-American Bar Association Committee on Continuing Professional Education, 1995 - Business & Economics - 1014 pages
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5th Cir acquired acquisition adjusted basis limitation affd alternative minimum tax amount at risk applicable arguably assets avoid beneficiary books method built-in gains capital gain carryover class of stock closing of books Comm'r compensation corporation level corporation's taxable December 31 deductions passthrough deferred determining dividend distribution election example excess filed former I.R.C. GDOT give rise holder income and deduction income tax increase interim closing items of income liability LIFO liquidation loan loss NUBIG ordinary income ownership partnership passive activity passthrough items payment percent potential prior Priv private letter rulings Prop purchase QSST qualify recapture recognition period recognized redemption reduced regulations related party remainderman return of capital rules share shareholder level shareholder's status stock basis straight debt Subchapter supra T.C. Memo tainted income target corporation taxable income taxation taxpayer termination tion transfer treated trust