 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 Tax Court of the United States - Page 750by United States. Tax Court - 1955Full view - About this book
 | United States. Internal Revenue Service - 1976 - 624 pages
...a corporation solely in exchange for stock or securities in such corporation if, immediately after the exchange, such person or persons are in control of the corporation to which the property was transferred. Section 351(c) of the Code provides that, for purposes of determining... | |
 | United States. Internal Revenue Service - 1977
...or more persons solely in exchange for stock or securities in such corporation and immediately after xD c IQY q i : H `H b q ps \ t Q Ci e- ; e `a _ ! Section 357 (a) of the Code provides, in part, that if a taxpayer receives property which would be... | |
 | United States. Internal Revenue Service - 1981 - 808 pages
...corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control of the corporation. Section 708 (a) of the Code provides that an existing partnership shall be considered as continuing... | |
 | United States. Tax Court - 1972 - 988 pages
...solely In exchange for stock or securities In such corporation, and Immediately after the eichange such person or persons are In control of the corporation...his interest In the property prior to the exchange. (Sec. 112(b)(5) was, Insofar as here pertinent, carried over substantially unchanged to the 1954 Code... | |
 | United States. Tax Court - 1971 - 1470 pages
...a corporation solely in exchange for stock or securities in such corporation, if Immediately after the exchange, such person or persons are in control of the corporation to which the property was transferred. As used in section 351, the phrase "one or more persons" includes... | |
 | United States. Commission on Revision of the Federal Court Appellate System - 1975 - 288 pages
...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." The Commissioner argued that under the "tax benefit" rule the transfer of 7395 S. Ct. 171, granting... | |
 | 1968 - 268 pages
...a corporation solely in exchange for stock or securities in such corporation, if immediately after the exchange, such person or persons are in control of the corporation to which the property was transferred. As used in section 351, the phrase "one or more persons" includes... | |
 | 2000 - 586 pages
...transfer property to a corporation solely in exchange for stock in the corporation and, immediately after the exchange such person or persons are in control of the corporation. Similarly, no gain or loss is recognized in the case of a contribution of property in exchange for... | |
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