...rule in those terms in the present context. We deal with § 351 (a) of the Code which provides: "No gain or loss shall be recognized if property is transferred...or persons are in control ... of the corporation." All that petitioners received from the corporations were securities equal in value to the net worth...

...rule in those terms in the present context. We deal with § 351 (a) of the Code which provides: "No gain or loss shall be recognized if property is transferred...or persons are in control ... of the corporation." All that petitioners received from the corporations were securities equal in value to the net worth...

...351 (b).8 • SEC. 351. TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. (a) GENERAL ROLE. — No gain or loss shall be recognized If property Is transferred...the exchange such person or persons are In control (as defined in section 368 (c)) of the corporation. For purposes of this section, stock or securities...

...$91,000.00 more over the 14 yrs. than Milo E. Wilson. OPINION Section 351 provides, in part, that no gain shall be recognized if property is transferred to...person or persons are in control of the corporation. 2 "Control" is defined for this purpose in section 368(c) as ownership of stock possessing at least...

...$91,000.00 more over the 14 yrs. than Milo E. Wilson. OPINION Section 351 provides, in part, that no gain shall be recognized if property is transferred to...exchange such person or persons are in control of the corporation.2 "Control" is defined for this purpose in section 368(c) as ownership of stock possessing...

...OR LOSS, (b) EXCHANGES SOLELY IN KIND. — • •»•**• (.") TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized...securities In such corporation, and Immediately after the eichange such person or persons are In control of the corporation ; but in the case of an exchange...

...RECOGNITION OF GAIN OR LOSS. (b) EXCHANGES SOLELY IN KIND. — ******* (5) TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized...solely in exchange for stock or securities in such conwration. and Immediately after the exchange such person or persons are in control of the corporation;...

...Revenue Code. Section 351 provides that no gain or loss shall be recognized if property is transfererd to a corporation by one or more persons solely in...immediately after the exchange such person or persons owns stock possessing at least 80% of the voting power and at least 80% of the total number of shares....

...(Conf.) (1982), to accompany HR 4961 (Pub. L. 97248), 1982-2 CB 600, 635. Section 35 16 provides that no gain or loss shall be recognized if property is transferred...persons solely in exchange for stock or securities in that corporation and immediately after the exchange the persons who transferred the property are in...

...agree with respondent that section 351 is inapplicable to this transaction. Section 351 applies where "property is transferred to a corporation * * * by...exchange for stock or securities in such corporation." Petitioners transferred their shares to a corporation for an agreement to pay an amount of cash plus...