 | United States. Congress. Joint Committee on Taxation - 1976 - 710 pages
...does not apply if the transferor can establish to the satisfaction of the Secretary that the transfer is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes. It is contemplated that ordinary business sales or exchanges involving an unrelated foreign trust will... | |
 | 1949 - 430 pages
...prior to the transfer it has been established to the satisfaction of the Commissioner that the transfer is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes. (c) Whether a transfer of stock or securities is in pursuance of a plan having as one of its principal... | |
 | 1981 - 1062 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).... | |
 | Richard A. Gordon - 1981 - 256 pages
...to the § 1491 tax are provided (1) for transfers to a tax exempt organization, (2) if the transfer is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes, (3) if § 367 applies to the transfer, or (4X/if an election to recognize gain on the transfer is made.... | |
 | 1987 - 776 pages
...before the transfer it has been established to the satisfaction of the Commissioner that the transfer is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes. (b) Whether a transfer of stock or securities is in pursuance of a plan having as one of its principal... | |
 | Joseph Isenbergh - 2006 - 966 pages
...it has been established to the satisfaction of the Commissioner that such exchange or distribution is not in pursuance of a plan having as one of its...principal purposes the avoidance of federal income taxes. 3 2 A device specifically targeted by Congress was the transfer by an individual of appreciated property... | |
 | 1957 - 898 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... | |
 | 1972 - 868 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 includlble In the gross Income of such person as a dividend under section 1248 (a).... | |
 | 2002 - 912 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 ineludible in the gross income of such person as a dividend under section 1248(a).... | |
 | 1960 - 630 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... | |
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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. 
