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International Economic Planning
Corporate Tax Problems
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2d Cir 5th Cir accounting acquired corporation adjusted basis aff'd agreement allocation amount apply assets capital gain carryover cash Charybdis claim Code collapsible Comm'r Commissioner corporation's cost creditor dealer debt debtor deduction depreciation determined distribution District dividend earnings and profits election entity expenses extent fair market value Federal filed gain or loss held holder income tax indebtedness Internal Revenue Code Internal Revenue Service inventory investment investor involved issue issuer levy LIFO method limited partnership ment merger mortgage obligation operating loss ordinary income parties partnership interest payment percent prior problem provides purchase real estate realized recapture received recognized Regulations reorganization Revenue Ruling ruling letters sale or exchange Section 337 selling share shareholders sold statute statutory subsidiary substantial supra tax benefit rule tax consequences Tax Court tax lien tax shelter taxable income Taxation taxpayer tion transaction transfer treatment trust United