...corporation controlled by transferor — (a) General rule. No gain or loss shall be recognized If property le transferred to a corporation by one or more persons...person or persons are in control (as defined in section 868 (c) ) of the corporation. For purposes of this section, stock or securities Issued for services...

...rule for the transfer of property to a corporation controlled by the transferor, now reads as follows: (a) General Rule. — No gain or loss shall be recognized...person or persons are in control (as defined in section 368(c)) of the corporation. For purposes of this section, stock or securities issued for services shall...

...question was "in effect" an exchange under section 351 " and, accordingly, that the gain realu SBC. 351. TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR....person or persons are In control (as defined In section 308 (c)> of the corporation. For purposes of this section, stock or securities issued for services...

...otherwise Indicated. 'SEC. 351. TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. (a) GENERAL ROLE. — No gain or loss shall be recognized If property Is transferred...section 368 (c)) of the corporation. For purposes of this section, stock or securities Issued for services shall not be considered as Issued in return for...

...gain realu SEC. 351. TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. (a) GENERAL RULE. — No gntn or loss shall be recognized If property Is transferred...section 368 (c)) of the corporation. For purposes of this section, stock or securities Issued for services shall not be considered as Issued In return for...

...avoidance within the meaning of section 367. LAW AND ANALYSIS Section 351 of the Code provides that no gain or loss shall be recognized if property is transferred...(as defined in section 368 (c) ) of the corporation. Section 367 (a) (1) of the Code provides that if, in connection with any exchange described in section...

...amount of gain recognized to the transferor on such transfer. Section 351(a) provides in pertinent part: (a) GENERAL RULE.— No gain or loss shall be recognized...person or persons are in control (as defined in section 368(c)) of the corporation. Petitioner argues that the general rule of sections 1011 and 1012 applies,...

...operate as life insurance companies. Section 351 of the Code provides, in part, that no gain or loss will be recognized if property is transferred to a corporation...(as defined in section 368 (c)) of the corporation. Section 357 (c) of the Code provides, in part, that if the sum of the amount of liabilities assumed...

...stock received by them in the exchanges. Section 351 (a) of the Code provides that no gain or loss will be recognized if property is transferred to a corporation...(as defined in section 368 (c) ) of the corporation. Section 368 (c) defines control to mean the ownership of stock possessing at least 80 percent of the...

...the property transferred. Section 351 (a) of the Code provides, in part, that no gain or loss will be recognized if property is transferred to a corporation...(as defined in section 368 (c)) of the corporation. Section 368 (c) of the Code provides that the term "control" means the ownership of stock possessing...