...preferred stock. Section 115, which concerns distributions by corporations, provides in subsection (c) that "amounts distributed in partial liquidation of a corporation...in part or full payment in exchange for the stock," thus according any gain realized the benefit of capital gains treatment. A partial liquidation is defined...

...contends represented « SEC. 115. DISTRIBUTIONS BY CORPOEATIONS. »«•••». (c) DISTRIBUTIONS IN LIQUIDATION. — Amounts distributed In complete...treated as in full payment in exchange for the stock • • •. The gain or loss to the distributee resulting from such exchange shall be determined under...

...X had no other stock outstanding. LAW AND ANALYSIS Section 331 (a) ( 1 ) of the Code provides that amounts distributed in complete liquidation of a corporation...treated as in full payment in exchange for the stock. The legislative background of section 331 (a) (1) of the Code indicates that Congress intended to have...

...*••*• • (c) DISTRIBUTIONS IN LIQUIDATION. — Amounts distributed In complete liquidation of • corporation shall be treated as In full payment in exchange for the stock, and amounts N8) asset value. It does not follow, however, that the petitioner sustained a short term capital loss...

...earnings and profits at the time the distribution was made. • ••••• • (c) DISTRIBUTION IN LIQUIDATION. — Amounts distributed In complete...liquidation of a corporation shall be treated as In fall payment In exchange for the stock, and amounts distributed In partial liquidation of a corporation...

...provides that amounts distributed in partial liquidation of a corporation (as defined in section 346) shall be treated as in part or full payment in exchange for the stock. Section 346 (a) (2) of the Code provides, in part, that a distribution shall be treated as in partial...

...interest in the redeeming company. Section 302 (a) of the Code provides that a distribution of property shall be treated as in part or full payment in exchange for the stock. Section 1001 of the Code provides for the recognition of gain from the sale or other disposition of...

...provides that amounts distributed in partial liquidation of a corporation (as described in section 346) Regulations was allowed to S for 1976. It was determined by the Dist pursuant to section 1001. Section 1001 of the Code provides for the recognition of gain from the sale...

...provides that amounts distributed in partial liquidation of a corporation (as defined in section 346) shall be treated as in part or full payment in exchange for the stock. Section 332 of the Code, in part, provides for nonrecognition of gain or loss by a parent corporation...

...provides that amounts distributed in partial liquidation of a corporation (as defined in section 346) shall be treated as in part or full payment in exchange for the stock. Section 1.331-1 (c) of the Income Tax Regulations provides that a liquidation that is followed by a...