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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 240
by United States. Tax Court - 1963
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Code of Federal Regulations: Containing a Codification of Documents of ...

1970
...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...
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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
...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
...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
...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
...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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Reports of the United States Tax Court, Volume 57

United States. Tax Court - 1972
...• •»•**• (.") 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 - 177 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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Reports of the United States Tax Court, Volume 56

United States. Tax Court - 1971
...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;...
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Reports of the United States Tax Court, Volume 89

United States. Tax Court - 1988
...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...
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Reports of the United States Tax Court, Volume 55

United States. Tax Court - 1970
...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...
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