 | United States. Congress. House. Committee on Ways and Means - 1973 - 524 pages
...Commissioner of Internal Revenue has determined in advance of the transaction that the transaction is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes. As a practical matter, this means that before the transaction the taxpayer must obtain a private ruling... | |
 | United States. Congress. House. Committee on Ways and Means - 1975 - 838 pages
...such exchange, it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having as one...principal purposes the avoidance of federal income taxes. Sections 1491 and 1492, enacted at the same time and for a similar purpose, provide that an excise... | |
 | United States. Congress. House. Committee on Ways and Means - 1975 - 348 pages
...the benefits of these provisions unless the taxpayer obtains a Treasury ruling prior thereto that the "exchange is not in pursuance of a plan having as...principal purposes the avoidance of Federal income taxes. " We believe the requirement that a ruling be obtained before the event should be eliminated in all... | |
 | United States. Congress. House. Committee on Ways and Means - 1975 - 914 pages
...benefits of these provisions unless the taxpayer obtains a Treasury ruling prior thereto that the "exhange is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal Income taxes." We beiieve the requirement that a ruling be obtained before the event should be eliminated in all circumstances... | |
 | 1949 - 774 pages
...been established to the satisfaction of the Commissioner that such transfer, exchange, or liquidation is not in pursuance of a plan having as one of its...income taxes. The term "Federal income taxes" includes (1) the excess-profits tax on the net income of a corporation referred to in section 106 of the Revenue... | |
 | 1968 - 268 pages
...such exchange, it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having as one...principal purposes the avoidance of Federal income taxes. For purposes of this section, any distribution described in section 355 (or so much of section 356... | |
 | United States. Congress. Senate. Committee on Finance - 1976 - 582 pages
...non-recognition), unless prior to the exchange it establishes to the satisfaction of the Commissioner that the exchange is not in pursuance of a plan having as one...principal purposes the avoidance of federal income taxes. Problems The amendments to §367 (a) were intended, according- to the Report of the> House Ways and... | |
 | 1970 - 772 pages
...no gain is recognized as a result of a determination by the Commissioner under section 367 that the exchange is not in pursuance of a plan having as one...principal purposes the avoidance of Federal income taxes, then no amount is includible in the gross income of such person as a dividend under section 1248 (a).... | |
 | United States - 1976 - 424 pages
...by regulations by the Secretary), it is established to the satisfaction of the Secretary that such exchange is not in pursuance of a plan having as one...principal purposes the avoidance of Federal income taxes. "(2) EXCEPTION FOR TRANSACTIONS DESIGNATED BY THE SECRETARY. — Paragraph (1) shall not apply to any... | |
 | 1966 - 468 pages
...no gain is recognized as a result of a determination by the Commissioner under section 367 that the exchange is not in pursuance of a plan having as one...principal purposes the avoidance of Federal income taxes, then no amount is includible in the gross income of such person as a dividend under section 1248 (a).... | |
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... it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes. 
