 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 U.S. Board of Tax Appeals - Page 3by United States. Board of Tax Appeals - 1934Full view - About this book
 | United States. Tax Court - 1972 - 988 pages
...TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized If property Is transferred to a corporation by one or more persons...securities In such corporation, and Immediately after the eichange such person or persons are In control of the corporation ; but in the case of an exchange... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1971 - 196 pages
...similar provision to domestic transactions and the revenue loss which such an extension might entail. solely in exchange for stock or securities in such...immediately after the exchange such person or persons owns stock possessing at least 80% of the voting power and at least 80% of the total number of shares.... | |
 | United States. Tax Court - 1970 - 1228 pages
...respondent that section 351 is inapplicable to this transaction. Section 351 applies where "property is transferred to a corporation * * * by one or more...exchange for stock or securities in such corporation." Petitioners transferred their shares to a corporation for an agreement to pay an amount of cash plus... | |
 | United States. Tax Court - 1971 - 1470 pages
...TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — 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 conwration. and Immediately after the exchange such person or persons are in control of the corporation;... | |
 | United States. Tax Court - 1989 - 1448 pages
...within section 351. Section 351 (a) provides that no gain or loss shall be recognized if (1) property is transferred to a corporation by one or more persons solely in exchange for stock or securities in that corporation and (2) immediately after the exchange the transferors of the property are in control... | |
 | United States. Congress. House. Committee on Ways and Means - 1971 - 324 pages
...Funds, investors' stock "is transferred to a corporation [the Fund} . . . in exchange for stock . . . in such corporation and immediately after the exchange such person or persons [investors] are in control . . . of the corporation". The issue, therefore, really is, why should the... | |
 | 1973 - 310 pages
...corporation (Including, In the case of transfers made on or before June 30, 1967, an Investment company) b; one or more persons solely In exchange for stock or...the exchange such person or persons are In control (as defined In section 3C8(c) ) of the corporation. For purposes of this section, stock or securities... | |
 | 1973 - 288 pages
...made on or before June 30, 1967, an Investment company) by one or more persons solely In excbange fot stock or securities In such corporation and Immediately...the exchange such person or persons are In control (as defined In section 368(c) ) oí the corporation. For pur- i poses of this section, stock or securities... | |
 | United States. Congress. House. Committee on Ways and Means - 1973 - 432 pages
...Funds, investors' stock "is transferred to a corporation [the Fund] . . . in exchange for stock . . . in such corporation and immediately after the exchange, such person or persons [the investors] are in control . . . of the corporation". The issue, therefore, really is, why should... | |
 | United States. Commission on Revision of the Federal Court Appellate System - 1975 - 292 pages
...transaction." Under section 351 of the Internal Revenue Code, gain or loss is not recognized "if property is transferred to a corporation .. . by one or more persons...or persons are in control ... of the corporation." The Commissioner argued that under the "tax benefit" rule the transfer of 7395 S. Ct. 17l, granting... | |
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