| United States. Internal Revenue Service - 1974
...immediately prior to the transfer. Section 368(a) (1) (D) of the Code defines a "reorganization" in part, as 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 is in control of the corporation to which the assets are transferred;... | |
| United States. Internal Revenue Service - 1974 - 624 pages
...that provision. Section 368(a) ( 1 ) (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. Tax Court - 1961 - 1226 pages
...The term "reorganization" means • • • (D) a transfer by a corporation of »H or a part of Us assets to another corporation If Immediately after...or both are In control of the corporation to which tie The governing legal rule can hardly be stated more narrowly. To attempt to do so would only challenge... | |
| United States. Internal Revenue Service - 1977
...extent of "other property." 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, is in control of the corporation to which the assets are transferred;... | |
| United States. Internal Revenue Service - 1979 - 644 pages
...368(a)(l)(D), 368(a) (1) (F), and 357(c). Section 368(a) (1) (D) states that the term "reorganization" means 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, or any combination thereof, is in control of the corporation to which... | |
| United States. Tax Court - 1968 - 1066 pages
...through the stockholders as a conduit.7 Under section 368 (a) (1) (D), 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, is in control of the corporation to which the assets are transferred.... | |
| United States. Internal Revenue Service - 1978 - 636 pages
...the corporation. Section 368 (a) (1) (D) of the Code provides that the term "reorganization" means 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 - 1978 - 630 pages
...transferred property. Section 368(a) (1) (D) of the Code provides, in part, that a reorganization includes a transfer by a corporation of all or a part of its...corporation if, immediately after the transfer, the tranferring corporation, or one or more of its shareholders, or any combination thereof, is in control... | |
| United States. Tax Court - 1967 - 1032 pages
...the fact that property acquired is subject to a liability, shall be disregarded ; (D) a transfer by n corporation of all or a part of Its assets to another...Immediately after the transfer the transferor, or one or more of Its shareholders (Including persons who were shareholders Immediately before the transfer),... | |
| United States. Tax Court - 1950 - 1144 pages
...transfer K' a corporation of all or a part of Its assets to another corporation If immediately after tbe transfer the transferor or Its shareholders or both...the corporation to which the assets are transferred • • *. (2) The term "a party to a reorganization" Includes a corporation resulting from « reorganization... | |
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