...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...exchange such person or persons are In control (as denned In section 368(c) ) of the corporation. For purposes of this section, stock or securities Issued...

...EXCHANGES SOLELY IN KIND. — ******* (5) TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized if property is transferred...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;...

...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....

...Internal Revenue Code of 1964, a* In effect during the tax years In Issue, unless otherwise noted. • SEC. 351. TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR....recognized If property Is transferred to a corporation (Including, In the case of transfers made on or before June 30, 1967, an Investment company) by one...

...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...

...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...

...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....

...corporations' stock. The transfer was within the terms of § 351 of the Code, which provides that no gain or loss shall be recognized if property is transferred to a corporation in exchange for stock, if after the exchange the transferors are in control of the corporation. The...

...corporations' stock. The transfer was within the terms of § 351 of the Code, which provides that no gain or loss shall be recognized if property is transferred to a corporation in exchange for stock, if after the exchange the transferors are in control of the corporation. The...

...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...