 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
 | Jacob Stewart Seidman - 2003 - 972 pages
...the proper rule for determining whether the stock received in an exchange by two or more persons is "in proportion to his interest in the property prior to the exchange" in cases involving assumption of liabilities. For this purpose, the amendment requires that the amount... | |
 | 2003 - 1082 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." See lRC § 351(a). Section 351(b) provides that if an exchange would be subject to section 351(a) but... | |
 | United States - 1939 - 780 pages
...more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control...his interest in the property prior to the exchange. (6) PROPERTY RECEIVED BY CORPORATION ON COMPLETE UQUIDATION OF ANOTHER. — No gain or loss shall be... | |
 | Glenn R. Carrington - 2007 - 744 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." The transferor's basis in the stock received is the same as the basis in the property transferred.1... | |
 | CCH Tax Law Editors - 2008 - 2242 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... | |
| |
