...distribution to its shareholders, prior to the realization by the corporation manufacturing, constructing, producing, or purchasing the property of a substantial...shareholders of gain attributable to such property. See §1.341-5 for a description of the facts which will ordinarily be considered sufficient to establish...

...or a distribution to them prior to the realization by the corporation manufacturing, constructing, producing, or purchasing the property of a substantial...taxable income to be derived from such property, and the realization by the shareholders of gain attributable to such property. This requirement is satisfied...

...or a distribution to them prior to the realization by the corporation manufacturing, constructing, producing, or purchasing the property of a substantial part of the taxable income to be derived trom such property, and the realization by the shareholders of gain attributable to such property....

...distribution to its shareholders, before the realization by the corporation manufacturing, constructing, producing, or purchasing the property of a substantial...shareholders of gain attributable to such property. Section 341 (b) (2) of the Code provides, in part, as follows : 1 • • For purposes of paragraph...

...distribution to its shareholders, before the realization by the corporation manufacturing, constructing, producing, or purchasing the property of a substantial...shareholders of gain attributable to such property. Whether the five subsidiary corporations fall within the definition of a collapsible corporation is...

...basis of $350,250. It appears, therefore, that the provisions of ration manufacturing, constructing, producing, or purchasing the property of a substantial...shareholders of gain attributable to such property. (2) PBODUCTION on PURCHASE or PROPERTY. — For purposes of paragraph (1), a corporation shall be deemed...

...realization by the corporation manufacturing, constructing, producing, or purchasing the property df a substantial part of the taxable Income to be derived...shareholders of gain attributable to such property. (2) PRODI CTIOX OR PURCHASE OF PIIOPEHTT. — For purposes of paragraph (1), a corporation shall be deemed...

...otherwise), * * * before the realization by the corporation manufacturing, constructing, producing * * * f the Treasury, Internal Revenue Service However, section 341 (d) (3) of the Code provides, in effect, that section 341 of the Code shall not...

...distribution to its shareholders, before the realization by the corporation * » * purchasing the projwrty of a substantial part of the taxable income to be...shareholders of gain attributable to such property. * * * » » * * (3) SECTION 341 ASSETS. — For purposes of this section, the term "section 341 assets"...

...distribution to its shareholders, before the realization by the corporation manufacturing, constructing, producing, or purchasing the property of a substantial...shareholders of gain attributable to such property. Section 341 (b) (2) of the Code provides, in part, that for purposes of section 341 (b) , a corporation...