 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
 | United States. Tax Court - 1971 - 1470 pages
...KIND. — ******* (5) TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized if property is transferred to a corporation...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;... | |
 | United States. Tax Court - 1988 - 1400 pages
...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 to a corporation...persons solely in exchange for stock or securities in that corporation and immediately after the exchange the persons who transferred the property are in... | |
 | United States. Tax Court - 1970 - 1228 pages
...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... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1971 - 196 pages
...similar provision to domestic transactions and the revenue loss which such an extension might entail. solely in exchange for stock or securities in such...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.... | |
 | United States. Tax Court - 1989 - 1448 pages
...falling within section 351. Section 351 (a) provides that no gain or loss shall be recognized if (1) property is transferred to a corporation by one or...persons solely in exchange for stock or securities in that corporation and (2) immediately after the exchange the transferors of the property are in control... | |
 | United States. Congress. House. Committee on Ways and Means - 1971 - 324 pages
...Funds, investors' stock "is transferred to a corporation [the Fund} . . . in exchange for stock . . . in such corporation and immediately after the exchange such person or persons [investors] are in control . . . of the corporation". The issue, therefore, really is, why should the... | |
 | Samuel S. Cross - 1972 - 706 pages
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 | 1973 - 310 pages
...corporation (Including, In the case of transfers made on or before June 30, 1967, an Investment company) b; one or more persons solely In exchange for stock or...the exchange such person or persons are In control (as defined In section 3C8(c) ) of the corporation. For purposes of this section, stock or securities... | |
 | 1984 - 424 pages
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