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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... "
Your Federal Income Tax for Individuals - Page 70
by United States. Internal Revenue Service - 1962
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Structure and Internal Procedures: Recommendations for Change

United States. Commission on Revision of the Federal Court Appellate System - 1975 - 292 pages
...nonrecognition transaction." Under section 351 of the Internal Revenue Code, gain or loss is not recognized "if property is transferred to a corporation .. ....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...
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The Code of Federal Regulations of the United States of America

1968 - 268 pages
...corporation (including, in the case of transfers made on or before June 30, 1967, an investment company) 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 (as defined...
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Tax Guide for Small Business

1961 - 764 pages
...where you exchange common stock in one corporation for common stock in another corporation. EXCHANGE OF PROPERTY FOR STOCK. If property is transferred to...persons solely in exchange for stock or securities in such corporation and such person or persons immediately after the exchange are in control of the corporation...
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Reports of the Tax Court of the United States, Volume 89

United States. Tax Court - 1988 - 1406 pages
...(Pub. L. 97248), 1982-2 CB 600, 635. Section 3516 provides that no gain or loss shall be recognized if property is transferred to a corporation by one...exchange for stock or securities in that corporation and immediately after the exchange the persons who transferred the property are in control of the corporation....
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Reports of the Tax Court of the United States, Volume 92

United States. Tax Court - 1989 - 1468 pages
...falling within section 351. Section 351 (a) provides that no gain or loss shall be recognized if (1) property is transferred to a corporation by one or...exchange for stock or securities in that corporation and (2) immediately after the exchange the transferors of the property are in control of the corporation.15...
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Report of Investigation of Enron Corporation and Related Entities Regarding ...

2003 - 1082 pages
...872 F 2d 519 (2d Cir 1989), Rev Rul. 64-155, 1964-1 CB 138 Generally, gain or loss is not recognized if property is transferred to a corporation 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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United States Statutes at Large, Volume 53, Part 1

United States - 1939 - 780 pages
...reorganization. (5) TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized if property is transferred to a corporation by one...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;...
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Bankruptcy and Insolvency Taxation

Grant W. Newton, Robert Liquerman - 2005 - 768 pages
...of a controlled corporation. IRC section 351 (a) provides that no gain or loss shall be recognized if property is transferred to a corporation 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 (as...
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Practical Guide to Mergers, Acquisitions and Business Sales

Joseph B. Darby - 2006 - 542 pages
...the scope of Code Sec. 351. Code Sec. 351 (a) provides that "[n]o gain or loss shall be recognized if property is transferred to a corporation 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 (as defined...
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Tax Accounting in Mergers and Acquisitions, 2008

Glenn R. Carrington - 2007 - 744 pages
...more fully, infra at <fl603.15.2. 16 Code §35l(a) provides that no gain or loss shall be recognized if property is transferred to a corporation 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 (as defined...
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