...of property acquired in a transaction described in paragraph (1), (2), (3), or (5) of subsection (d) is determined by reference to its basis in the hands of the transferor, then the holding period of the property in the hands of the transferee shall include the holding period...

..." (i) a transfer by reason of death, or " (ii) a transaction as a result of whioh the basis of the property in the hands of the transferee is determined...of the transferor by reason of the application of section 332, 351, 361, 371 (a), 374 (a), 721, or 731, and such property (or the property acquired tinder...

...decedent. The same treatment is also applied to certain specified transfers in which the basis of the property in the hands of the transferee is determined...reference to its basis in the hands of the transferor. The specified transfers are — (a) transfers to a corporation upon the liquidation of a subsidiary...

...a transfer at death. (3) Certain corporate transactions. If the basis of property in the hands of a transferee is determined by reference to its basis...of the transferor by reason of the application of sections 332, 351, 361, 371 (a), or 374(a), then the amount of gain taken into account by the transferor...

...Exception for certain tax-free transactions. If the basis of a subsection (f ) asset in the hands of a transferee is determined by reference to its basis...of the transferor by reason of the application of section 332, 351, 361, 371 (a), or 374 (a), then the amount of gain taken into account by the transferor...

...as follows: exceed the gain recognized to the transferor if "the basis of property in the hands of a transferee is determined by reference to its basis...of the transferor by reason of the application of section 332." The parent company, Branjon, was accorded nonrecognition treatment under section 332...

...Commissioner, 67 TC 1071, 1078(1977). Section 1251(a) provides for the applicability of the section determined by reference to its basis in the hands of the transferor by reason of the application of tection 332, 351, 361, 371(a), or 374(a), then the amount of gain taken into account by the transferor...

...transaction in which its basis in the hands of the transferee is determined in whole or in part by reference to its basis in the hands of the transferor by reason of the application of any provision of the Code, or in a transfer (including any purchase for cash or in exchange) from a related...

...Act) and section 1.382(a)( 1 ) (e) ( 1 ) (i) of the regulations thereunder, if the basis of the stock is determined by reference to its basis in the hands of the transferor thereof or of another person, or by reference of the basis of property (other than cash or its equivalent)...

...(2). Under paragraph (3) if the basis of subsection (f) asset in the hands of a transferee corporation is determined by reference to its basis in the hands of the transferor corporation by reason of the application of certain sections of the code providing for uonrecognition...