Immediately after the transfer an interest or control In such property of 80 per centum or more remained In the same persons or any of them, then the basis shall be the same as It would be In the hands of the transferor, Increased In the amount of gain... Reports of the Tax Court of the United States - Page 413by United States. Tax Court - 1947Full view - About this book
| United States. Court of Claims, Audrey Bernhardt - 1950 - 824 pages
...by a corporation in connection with a reorganization, and immediately after the transfer an interest or control in such property of 50 per centum or more...or any of them, then the basis shall be the same as it would be in the hands of the transferor * * *. Opinion of the Court It is conceded by the plaintiff... | |
| United States. Court of Claims, Audrey Bernhardt - 1958 - 966 pages
...by a corporation in connection with a reorganization, and immediately after the transfer an interest or control in such property of 50 per centum or more remained in the same persons or any of them, or (B) in a taxable year beginning after December 31. 1935, by a corporation in connection with a reorganization,... | |
| United States. Court of Claims, Audrey Bernhardt - 1955 - 928 pages
...a reorganization, and immediately after the transfer an interest or control in such property of 80 per centum or more remained in the same persons or any of them, then the hasis shall be the same as it would be in the hands of the transferor, increased in the amount of gain... | |
| United States. Court of Claims - 1941 - 858 pages
...only in the event that "immediately after the transfer an interest or control in such property of 80 per centum or more remained in the same persons or any of them." If such interest or control did not remain in such hands, then, of course, the general rule applied,... | |
| United States. Court of Claims - 1940 - 760 pages
...a reorganization, and immediately after the transfer an interest or control in such property of 80 per centum or more remained in the same persons or any of tfam, then the basis shall be the same as it would be in the hands of the transferor * * *. (Sec. 113... | |
| United States. Internal Revenue Service - 1924 - 396 pages
...a reorganization, and immediately after the transfer an interest or control in such property of 80 per centum or more remained in the same persons or...the amount of loss recognized to the transferor upon :^uch transfer under the law applicable to the year in which the transfer was made; (8) If the property... | |
| United States. Congress. Senate. Committee on Finance - 1924 - 468 pages
...transaction what the ultimate tax on such a transaction will be. Section 204 (a) (7) reads as follows: or any of them, then the basis shall * * * be the same as it would be in the hands of the transferor. * * *" A consistently uniform legislative policy has in... | |
| John F. Sherwood - 1925 - 206 pages
...a reorganization, and immediately after the transfer an interest or control in such property of 80 per centum or more remained in the same persons or...the amount of loss recognized to the transferor upon s uch transfer under the law applicable to the year in which the transfer was made; (8) If the property... | |
| Walter Elbert Barton, United States, Carroll Wright Browning - 1925 - 580 pages
...a reorganization, and immediately after the transfer an interest or control in such property of 80 per centum or more remained in the same persons or any of them then the basis shall be the same as it would be in the hands oJ value of such property at the time of such acquisition. The provisions... | |
| United States. Congress. House. Committee on Ways and Means - 1925 - 1154 pages
...a reorganization, and immediately after the transfer an interest or control of such property of 80 per centum or more remained in the same persons or any of them, then the basis shall be the same as it would be in the hands of the transferer." A consistently uniform legislative policy has In the past... | |
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