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accumulated acquiring corporation acquisition adjusted basis adoption amount applies assets assumed attributable basis beginning carry carryovers close Code complete computed considered constructive controlled Corporation's date of distribution December 31 deduction Department described determined distribution or transfer distributor or transferor dividend earnings and profits effect election Example excess exchange extent facts fair market value Federal gain gain or loss graph hands holders illustrated immediately included increase Internal Revenue Code January Less liability limitation liquidation loss carryovers meaning method of accounting operating loss outstanding stock ownership paid paragraph percent period person poration portion preceding prior provisions purchase pursuant ration realized received recognized redemption reference regulations relating reorganization requirements respect rule section 306 securities Service shareholder shares specific Statutory provisions subparagraph subsection taxable income taxable year ending term tion trade or business trans transaction transferor corporation treated tribution
Page 119 - ... it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes.
Page 67 - June 22, 1954, and (2) Within the 12-month period beginning on the date of the adoption of such plan, all of the assets of the corporation are distributed in complete liquidation, less assets retained to meet claims, then no gain or loss shall be recognized to such corporation from the sale or exchange by it of property within such 12-month period. (b) Property defined — (1) In general. For purposes of subsection (a), the term "property...
Page 101 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 125 - If It were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain, If any, to the recipient shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property.
Page 34 - Goods delivered, or to be delivered, to the extent the proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset, or (B) Services rendered or to be rendered, (c) Presumption in certain cases — (1) In general.
Page 125 - If the corporation receiving such other property or money distributes it in pursuance of the plan of reorganization, no gain to the corporation shall...
Page 125 - ... the gain, if any, to the corporation shall be recognized, but in an amount not in excess of the sum of such money and the fair market value of such other property to received, which is not so distributed.
Page 118 - ... then the basis shall be the same as it would be in the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year in which the transfer was made.
Page 188 - Secretary, expended in the acquisition of other property similar or related in service or use to the property so converted, or in the ac.quisition of control of a corporation owning such other property, or in the establishment of a replacement fund, no gain shall be recognized, but loss shall be recognized. If any part of the money is not so expended...
Page 217 - A corporation has not continued to carry on a trade or business substantially the same as that conducted before any increase in the ownership of its stock if the corporation is primarily engaged in the rendition of services by a particular individual or individuals and, after the increase in ownership, the corporation is primarily engaged in the rendition of services by different individuals. This subparagraph may be illustrated by the following examples: Example (1).