If an exchange would be within the provisions of subsection (b), (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without... Reports of the United States Tax Court - Page 503by United States. Tax Court - 1983Full view - About this book
| 1971 - 544 pages
...property permitted by such provisions to be received without the recognition of gain, but also oí other property or money, then the gain, If any, to...such money and the fair market value of such other property. [Sec. 1031 (b) as amended by sec. 201 (c). Act of Sept. 22, 1959 (Pub. LIUT 86-846, 73 Stat.... | |
| United States. Tax Court - 1970 - 1868 pages
...property received In the exchange consists not only of property permitted by section 354 or 355 to be received without the recognition of gain but also...recipient shall be recognized, but In an amount not In excera of the mm of such money and the fair market value of such other property. conceivable basis... | |
| United States. Tax Court - 1971 - 1470 pages
...If an exchange would be within the provisions of subsection (a), * * * If It were not for the fnct that the property received In exchange consists not...recognition of gain, but also of other property or monpy, then the sain, If any, to the recipient shall be recognized, but In an amount not In excess... | |
| 1971 - 272 pages
...reorganization, the gain, If any, to the corporation shall be recognized, but In an amount not In excès* of the sum of such money and the fair market value of such other property so received, which Is not so distributed. (3) Loss from exchanges not solely in kind. II an... | |
| United States. Tax Court - 1974 - 862 pages
...that the property received in the exchange consists not only of property permitted by that section to be received without the recognition of gain but also of "other property or money" (often referred to as boot), section 356 5 must be examined. Sec. 354(a)(3). Section 356(a)(l) provides... | |
| United States. Tax Court - 1970 - 1228 pages
...property received In exchange consists not only of stock or securities permitted by subsection (a) to be received without the recognition of gain, but also of other property or money, then — (A) If the corporation receiving such other property or money distributes it In pursuance... | |
| 1971 - 616 pages
...received without the recognition of gain, but also of other property or money, then an amount equal to the sum of such money and the fair market value of such other property shall be treated as a distribution of property to which section 301 applies. (c) Loss. If... | |
| 1973 - 288 pages
...exchange consists not only of property permitted by section 304 or 355 to be received without th» recognition of gain but also of other property or...such money and the fair market value of such other property. (2) Treatment as dividend. If an exchange Is described In paragraph (1) but has the effect... | |
| 1973 - 310 pages
...that the property received in exchange consists not only of property permitted by such subsection to be received without the recognition of gain, but also of other property or money, then the gaip, if any, to the recipient shall be recognized, but in an amount not in excess of the sum of such... | |
| Commission on the Bankruptcy Laws of the United States - 1973 - 746 pages
...circumstances if "the property received in exchange consists not only of property permitted by paragraph fl) to be received without the recognition of gain, but also of other property or money" (emphasis added). There is no provision, however, for nonrecognition of gain or loss (and hence none... | |
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