Mother corporation) or (B) a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor, or its stockholders, or both, are in control of the corporation to which the assets are transferred... Reports of the U.S. Board of Tax Appeals - Page 9by United States. Board of Tax Appeals - 1934Full view - About this book
| United States. Tax Court - 1963 - 1130 pages
...follows : fro tioi (P* Sec. 203 (h) As used In this section and sections 201 and 201 — • •*•**• (2) The term "a party to a reorganization" Includes a corporation resulting im a reorganization and includes both corporations in the case of an acqulsion by one corporation of... | |
| 1967 - 540 pages
...transferee was not actively engaged in business at the time of the acquisition, and (3) After such transfer, the transferor or its stockholders, or both, are in control of the transferee during any part of the taxable year of the transferee, unless, (4) The transferee establishes... | |
| 1969 - 1404 pages
...assets to another corporation if immediately after the transfer the transferor or its shareholders or both are in control of the corporation to which the assets are transferred; or (5) a recapitalization; or (6) a mere change in indentity, form, or place of organization, however... | |
| United States. Tax Court - 1954 - 1210 pages
...assets to another corporation If Immediately after the transfer the transferor or its shareholders or both are In control of the corporation to which the assets are transferred, or * • • • **•••• (h) DEFINITION OF CONTROL. — As used in this section the term "control"... | |
| United States. Tax Court - 1958 - 1372 pages
...TAX COURT OF UNITED STATES REPORTS. immediately after the transfer the transferor or its shareholders both are in control of the corporation to which the assets are transferred," or as defined in section 11:2 (g) (1) (F), ''a mere change in identity, form, or place of organization,... | |
| United States. Tax Court - 1951 - 1074 pages
...assets to another corporation If Immediately after the transfer the transferor or Its sbarebolders or both are In control of the corporation to which the assets are transferred. • • *. • SEC. 112. RECOGNITION OF GAIN OR LOSS. • •••••• Ib) EXCHANGES SOLELY IN... | |
| United States. Tax Court - 1943 - 1330 pages
...corporation of all or a part of its assets to another corporation if immediately after -^•ansfer the transferor or its stockholders or both are in control of the corporation ^iich the assets are transferred, or (D) a recapitalization, or (E) a mere change in ^tty, form, or... | |
| United States. Tax Court - 1956 - 1226 pages
...assets to another corporation If immediately after the transfer the transferor or Its shareholders or both are in control of the corporation to which the assets an transferred, or • • • • SEC. 112. RECOGNITION OF GAIN OR LOSS. (b) EXCHANGES SOLELY IN KIND.... | |
| United States. Tax Court - 1970 - 1228 pages
...(B) a transfer by a corporation ot all or a part of Its assets to another corporation If Immediately after the transfer the transferor or Its stockholders...the corporation to which the assets are transferred * • • 420-714—71 16 did not comply with these requirements of the statute. It never transacted... | |
| Commission on the Bankruptcy Laws of the United States - 1973 - 746 pages
...(C) a transfer by a corporation of all or part of its assets to another corporation if immediately after the transfer the transferor or its stockholders...corporation to which the assets are transferred, or (D) a recapitalization, or (E) a mere change in identity, form, or place of organization, however effected."... | |
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