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" Amounts distributed in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock, and amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the... "
Reports of the Tax Court of the United States - Page 259
by United States. Tax Court - 1955
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After Death Tax Planning: Minimizing Tax Liabilities

Francis J. Antonucci, Robert Whitman - 2004 - 316 pages
...shall be taken into account, including distributions which under another provision of the Code are treated as in part or full payment in exchange for the stock redeemed. Essentially, this provision indicates that each distribution uses up the benefit of the section...
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Bankruptcy and Insolvency Taxation

Grant W. Newton, Robert Liquerman - 2005 - 768 pages
...Distributions in Complete Liquidation Treated as Exchanges. Amounts received by a shareholder in a distribution in complete liquidation of a corporation shall be...treated as in full payment in exchange for the stock. (b) Nonapplication of Section 301. Section 301 (relating to effects on shareholder of distributions...
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International Taxation: U.S. Taxation of Foreign Persons and ..., Volume 1

Joseph Isenbergh - 2006 - 918 pages
...This general rule is encoded in section 331 (a): "Amounts received by a shareholder in a distribution in complete liquidation of a corporation shall be...treated as in full payment in exchange for the stock." The shareholders of a liquidating corporation are treated in effect as exchanging their stock for the...
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Income Tax Regulations, As of January 2008

CCH Tax Law Editors - 2008 - 2242 pages
...complete or partial liquidation of a corporation. Under section 331(a)(l), it is provided that amounts distributed in complete liquidation of a corporation...treated as in full payment in exchange for the stock. Under section 331(a)(2), it is provided that amounts distributed in partial liquidation of a corporation...
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