| United States. Internal Revenue Service - 1962 - 976 pages
...acquired la subject to a liability, shall be disregarded, or (D) a transfer by a corporation of all or part of Its assets to another corporation If Immediately...transferor or Its shareholders or both are In control of fie corporation to which the assets are transferred, or (B) a recapitalization, or (F) mere change... | |
| 1969 - 1404 pages
...the other, or the fact that property acquired is subject to a liability, shall be disregarded; or (4) a transfer by a corporation of all or a part of its...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 - 1949 - 1378 pages
...reduced to writing, Bortense A. Menefee, 46 BTA 865 ; 1 (1) The term "reorganization" means • » • (D) a transfer by a corporation of all or a part of...the corporation to which the assets are transferred • • *. 1 (4) • • • No gain or loss shall be recognized If a corporation a party to a reorganization... | |
| United States. Tax Court - 1956 - 1226 pages
...• (g) DEFINITION or REORGANIZATION. — • • • (1) The term "reorganization" means • • • (D) a transfer by a corporation of all or a part of...both are In control of the corporation to which the axels are transferred • • • supporting the view that petitioner owed $6,050 to Motor Sales because... | |
| United States. Tax Court - 1951 - 1074 pages
...(22)). — (1) The term "reorganization" means (A) a statutory merger or consolidation. • • • or (D) a transfer by a corporation of all or a part...Immediately after the transfer the transferor or Its sbarebolders or both are In control of the corporation to which the assets are transferred. • •... | |
| United States. Tax Court - 1970 - 1856 pages
...purposes of parts I and II and this part, the term "reorganization" means — • •••••• (D) a transfer by a corporation of all or a part of...Immediately after the transfer the transferor, or one or more of Its shareholders (Including persons who were shareholders Immediately before the transfer),... | |
| United States. Internal Revenue Service - 1975 - 652 pages
...Revenue is required. Section 368(a)(l)(D) of the Code provides that the term "reorganization" includes a transfer by a corporation of all or a part of its...immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders immediately before the transfer),... | |
| United States. Internal Revenue Service - 1976 - 624 pages
...in exchange for M currency. Section 368(a) (1) (D) of the Code defines a "reorganization" to include a transfer by a corporation of all or a part of its...immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders immediately before the transfer)... | |
| United States. Internal Revenue Service - 1972 - 624 pages
...beginning of such period. Section 368(a) (1) (D) of the Code provides that a reorganization includes a transfer by a corporation of all or a part of its...immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders immediately before the transfer)... | |
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