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Stock Redemptions Partial Liquidations Preferred
7 other sections not shown
5th Cir accumulated earnings tax acquiring corporation acquisition adjusted adjusted basis adoption allocation amount apply Bardahl basis bution capital gain cash collapsible corporation Commissioner common stock complete liquidation computing corporate shareholder corporation's debt deduction depreciation determined distri earnings and profits excess fair market value February 28 filed gain or loss holder holding company income income tax installment obligations inventory investment Kimbell-Diamond rule liabilities liquidating corporation liquidating distribution liquidation plan ment nonrecognition ordinary gross income ordinary income parent corporation partial liquidation period personal holding company plan of liquidation poration preferred stock property received provides purchase purpose pursuant qualify recapture recognized gain reorg reorganization result rule of section sale or exchange Section 337 share shareholders statutory stockholders Sub-S subsidiary subsidiary's stock target corporation tax consequences tax-free taxable income taxpayer tion transaction transfer Treas treated treatment twelve month voting stock