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ADVISORY BOARD MEETING allocation amended amount apply assets basis beneﬁciary beneﬁt capital gains carryover cash Commissioner Company Comr Cong corporation deduction deﬁciency deﬁned deﬁnition determination distribution dividend earnings and proﬁts employee ERISA estate tax Executive Compensation expenses ﬁle ﬁled ﬁrst Foreign Income gift gift tax grantor held income tax interest Internal Revenue Code Internal Revenue Service liability limited partnership liquidation loss MEMORANDUM ment ofﬁce ofthe option ordinary income ownership paid partner payments percent poration preferred stock prior provides Puerto Rico purchase purposes qualiﬁed received redemption regulations reorganization Revenue Code Revenue Ruling Senate Sess shareholders Silverstein and Mullens speciﬁc statutory Subscribers whose subscription subsidiary T.C. Memo Tax Court Tax Management Tax Reform Act taxable taxpayer tion trade or business transaction transfer Treas treatment trust U.S. Tax United USTC Wickersham and Taft York City