... one or more persons solely In exchange for stock or securities In such corporation, and immediately after the exchange such person or persons are In control of the corporation ; but in the case of an exchange by two or more persons this paragraph... Reports of the Tax Court of the United States - Page 632by United States. Tax Court - 1959Full view - About this book
| United States. Court of Claims - 1947 - 806 pages
...corporation ; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each...his interest in the property prior to the exchange. The taxpayer says that his receipt of the stock was not a tax-free transaction because the stock of... | |
| United States. Court of Claims, Audrey Bernhardt - 1959 - 1028 pages
...corporation ; but In the case of an exchange by two or more persons I Ms paragraph shall apply only If the amount of the stock and securities received by each is substantially in proportion to bis Interest In the property prior to the exchange. • • •" ' Both plaintiffs and defendant regarded... | |
| United States. Court of Claims, Audrey Bernhardt - 1955 - 928 pages
...having satisfied the requirements of section 112 they are entitled, under section 113 (a) by each la substantially in proportion to his interest in the property prior to the exchange. • • • * • (i) Definition of reorganization. — As used in this section and sections 113 and... | |
| United States. Internal Revenue Service - 1924 - 396 pages
...corporation; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each...his interest in the property prior to the exchange. (5) If property (as a result of its destruction in whole or in part, theft or seizure, or an exercise... | |
| John F. Sherwood - 1925 - 206 pages
...corporation ; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each...his interest in the property prior to the exchange. into property similar or related in service or use to the property so converted, or into money which... | |
| Walter Elbert Barton, United States, Carroll Wright Browning - 1925 - 580 pages
...corporation ; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each...his interest in the property prior to the exchange. (5) If property (as a result of its destruction in whole or in part, theft or seizure, or an exercise... | |
| Irving Bank-Columbia Trust Company - 1925 - 152 pages
...corporation; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each...his interest in the property prior to the exchange. (5) If property (as a result of its destruction in whole or in part, theft or seizure, or an exercise... | |
| Joseph Henry Beale, Roswell Foster Magill - 1926 - 744 pages
...corporation; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each...his interest in the property prior to the exchange. (5) If property (as a result of its destruction in whole or in part, theft or seizure, or an exercise... | |
| United States. Congress. Joint Committee on Internal Revenue Taxation - 1927 - 414 pages
...corporation; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each...his interest in the property prior to the exchange. (c) Gain from exchanges not solely in kind. — (1) If an exchange would be within the provisions of... | |
| Nathan William MacChesney - 1927 - 960 pages
...if immediately after the exchange such persons are in control of the corporation, and the amount of stock and securities received by each is substantially...his interest in the property prior to the exchange.* If, however, an exchange fails to come under the above provisions because of the fact that the property... | |
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