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... Reports of the Tax Court of the United States - Page 234by United States. Tax Court - 1963Full view - About this book
| 1970 - 1320 pages
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| United States. Tax Court - 1975 - 1262 pages
...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 a corporation...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... | |
| United States. Tax Court - 1975 - 1272 pages
...351. TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. (a) GENERAL RULE.—No gain or loss shall be recognized if property is transferred to a corporation...the exchange such person or persons are in control (as defined in section 368(c)) of the corporation. * * * In this case, respondent is in the unusual... | |
| United States. Tax Court - 1972 - 988 pages
...• •»•**• (.") TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized If property Is transferred to a corporation...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... | |
| United States. Congress. Senate. Foreign Relations - 1971 - 186 pages
...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.... | |
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