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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... "
Reports of the Tax Court of the United States - Page 234
by United States. Tax Court - 1963
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American Federal Tax Reports, Volume 2; Volume 24

1970 - 1320 pages
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 398

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1971 - 732 pages
...the present context. We deal with § 351 (a) of the Code which provides: "No gain or loss shall be recognized if property is transferred to a corporation...or persons are in control ... of the corporation." All that petitioners received from the corporations were securities equal in value to the net worth...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 398

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1971 - 738 pages
...the present context. We deal with § 351 (a) of the Code which provides: "No gain or loss shall be recognized if property is transferred to a corporation...or persons are in control ... of the corporation." All that petitioners received from the corporations were securities equal in value to the net worth...
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Reports of the United States Tax Court, Volume 65

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...
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Reports of the United States Tax Court, Volume 65

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...
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Professional Corporations Handbook

Commerce Clearing House - 1971 - 1098 pages
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Journal - State Bar of California, Volume 27

State Bar of California - 1952 - 486 pages
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Reports of the United States Tax Court, Volume 57

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...
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Tax Conventions with Belgium, Finland, Trinidad and Tobago, and the ...

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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