 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. Commission on Revision of the Federal Court Appellate System - 1975 - 288 pages
...351 nonrecognition transaction." Under section 351 of the Internal Revenue Code, gain or loss is not recognized "if property is transferred to a corporation...or persons are in control ... of the corporation." The Commissioner argued that under the "tax benefit" rule the transfer of 7395 S. Ct. 171, granting... | |
 | 1963 - 730 pages
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 | California - 1975 - 878 pages
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 | John R. Walker - 1976 - 268 pages
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 | 1968 - 268 pages
...corporation (including, in the case of transfers made on or before June 30, 1967, an investment company) by one or more persons solely in exchange for stock...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... | |
 | Alabama - 1977 - 726 pages
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 | United States. Internal Revenue Service - 1955 - 656 pages
...exchange common stock in one corporation for common stock in another corporation. PROPERTY FOR STOCK. If property is transferred to a corporation by one...exchange for stock or securities in such corporation and such person or persons immediately after the exchange are in control of the corporation to which the... | |
 | 1980 - 340 pages
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 | United States. Internal Revenue Service - 1975 - 196 pages
...transferred to a corporation by one or more persons solely in exchange for stock or securities in that corporation and immediately after the exchange such person or persons are in control p1 the corporation to which the property was transferred, ordinarily no gain or loss will be recognized.... | |
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