 | United States. Tax Court - 1947 - 1642 pages
...disposition of the shares in >Sec. 112 (b) (5). TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR.—No gala or loss shall be recognized If property Is transferred...securities In such corporation, and immediately after rlexchange such person or persons are In control of the corporation; • • • 'Sec. 113 (a). BASIS... | |
 | United States. Tax Court - 1947 - 1314 pages
...petitioner's transferor (the old company) . Section 112 (b) (5), Internal Kevenue Code, provides: (5) No gain or loss shall be recognized if property is transferred...or securities in such corporation, and immediately alter the exchange such person or persons are in control of the corporation * * *. [Emphasis supplied.]... | |
 | United States. Tax Court - 1950 - 1992 pages
...9.588 64 4.851.10 Ho gain or loss shall be recognized If property is transferred to a corporation bj one or more persons solely in exchange for stock or...person or persons are In control of the corporation; * * * Section 112 (c) (1) provides: If an exchange would be within the provisions of subsection (b)... | |
 | United States. Internal Revenue Service - 1978 - 630 pages
...commitment" underwriting. Section 351 (a) of the Code provides, in part, that no gain or loss will i the transferors are in control (as defined in section 368(c) ) of the corporation. Section 368 (c)... | |
 | United States. Tax Court - 1959 - 1470 pages
...• • • • (B) TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall he recognized If property Is transferred to a corporation...such corporation, and Immediately after the exchange snch person or persons are In control of the corporation ; but In the case of an exchange by two or... | |
 | United States. Tax Court - 1949 - 1378 pages
...stock s«urltles) * * *. 'SEC. 112. RECOGNITION OF GAIN OR LOSS. • ••••• (b) • . • (5> TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR.—...transferred to a corporation by one or more persons solely ID 'change for stock or securities In such corporation, and Immediately after the exchange c" Person... | |
 | United States. Internal Revenue Service - 1975 - 804 pages
...realized by У on the transfer. Section 351 (a) of the Code provides, in part, that no gain or loss will be recognized if property is transferred to a corporation...exchange for stock or securities in such corporation if immediately after the exchange such person or persons are in control (as defined in section 368... | |
 | United States. Internal Revenue Service - 1977
...construction business after the transaction. Section 351 (a) of the Code provides that no gain or loss will r purposes of his federal income tax. Griffiths v. Commissioner, if immediately after the exchange the transferors are in control of the corporation as defined in section... | |
 | United States. Tax Court - 1956 - 1226 pages
...of book value had been transferred to the corpora1 Section 112 (b) (5) provides that "No gain or Ion shall be recognized If property Is transferred to...persons solely In exchange for stock or securities In Buch corporation, and Immediately after the exchange inch person or persons are In control of the corporation... | |
 | United States. Internal Revenue Service - 1981 - 808 pages
...in a partnership composed of S, Y, and Z. LAW AND ANALYSIS Section 351 of the Code provides that no gain or loss shall be recognized if property is transferred...by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control of the... | |
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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... 
