No gain or loss shall be recognized If property is transferred to a corporation by 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... Reports of the U.S. Board of Tax Appeals - Page 125by United States. Board of Tax Appeals - 1941Full view - About this book
| United States. Court of Claims - 1947 - 806 pages
...whereas the taxpayer thinks it is governed by section 203 (b) (4) . Section 203 (b) (4) provides: No gain or loss shall be recognized if property is transferred...amount of the stock and securities received by each is substantially in proportion to his interest in the property prior to the exchange. The taxpayer... | |
| United States. Court of Claims, Audrey Bernhardt - 1959 - 1028 pages
...section. "(b) Exchanges solely In kind — "(5) Transfer to corporation controlled by transferor. No gain or loss shall be recognized If property Is transferred...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... | |
| United States. Court of Claims, Audrey Bernhardt - 1955 - 928 pages
...non-recognition of gain or loss under section 112 (b) (5) of the Revenue Act of 1928. This section provides : No gain or loss shall be recognized if property is transferred...exchange for stock or securities in such corporation, * * * [Emphasis supplied.] In order for plaintiffs to come within this section they must show that... | |
| United States. Court of Claims - 1932 - 800 pages
...upon the constitutionality of section 204 (a) (8) of the revenue act of 1924, which provides that no gain or loss shall be recognized, if property is transferred to a corporation, in exchange for stock or securities in «uch corporation, and immediately after the exchange the transferor... | |
| United States. Internal Revenue Service - 1924 - 396 pages
...reorganization, solely for stock or securities iu another corporation a party to the reorganization. (4) No gain or loss shall be recognized if property is transferred...persons solely in exchange for stock or securities in Buch corporation, and immediately after the exchange such person or persons are in control of the corporation;... | |
| Walter Elbert Barton, United States, Carroll Wright Browning - 1925 - 580 pages
...of 1918. solely for stock or securities in another corporation a party to the reorganization. (4) No gain or loss shall be recognized if property is transferred...amount of the stock and securities received by each is substantially in proportion to his interest in the property prior to the exchange. (5) If property... | |
| John F. Sherwood - 1925 - 206 pages
...reorganization, solely for stock or securities in another corporation a party to the reorganization. (4) No gain or loss shall be recognized if property is transferred...amount of the stock and securities received by each is substantially in proportion to his interest in the property prior to the exchange. into property... | |
| Irving Bank-Columbia Trust Company - 1925 - 152 pages
...reorganization, solely for stock or securities in another corporation a party to the reorganization. (4) No gain or loss shall be recognized if property is transferred...amount of the stock and securities received by each is substantially in proportion to his interest in the property prior to the exchange. (5) If property... | |
| Joseph Henry Beale, Roswell Foster Magill - 1926 - 744 pages
...corporation. (c) If property, real, personal, or mixed, is transferred to a corporation ( 1 ) by one person solely in exchange for stock or securities in such...corporation, and immediately after the exchange such person is in control of the corporation, or (2) by two or more persons, solely in exchange for stock or securities... | |
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