 ... who were shareholders immediately before the transfer), or any combination thereof, is in control of the corporation to which the assets are transferred; but only if, in pursuance of the plan, stock or securities of the corporation to which the assets...  Reports of the Tax Court of the United States - Page 75by United States. Tax Court - 1970Full view - About this book
 | Administrative law - 1940 - 1806 pages
...are In control of the corporation to which, the assets are transferred, or (E) a recapitalization, or e claim, or, n no claim was filed, then during the three years Immediately preced (c) REQUIREMENT OF SUBSTANTIALLY PROPORTIONATE INTERESTS. Section 112 (b) (6) of the Internal Revenue... | |
 | United States - Law - 1965 - 1110 pages
...immediately before the transfer) , or any combination thereof, is in control of the corporation to which the assets are transferred; but only if, in pursuance...to which the assets are transferred are distributed ma transaction which qualifies under section 354, 355, or 356; (E) a recapitalization; or (F) a mere... | |
 | United States - Law - 1953 - 1744 pages
...are in control of the corporation to which the assets are transferred, or (E) a recapitalization, or (F) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization" includes a corporation resulting from a reorganization and... | |
 | United States. Internal Revenue Service - Taxation - 1941 - 664 pages
...are in control of the corporation to which the assets are transferred, or (E) a recapitalization, or (F) a mere change in identity, form, or place of organization, however effected. (c) REQUIREMENT OF SUBSTANTIALLY PROPORTIONATE INTERESTS. — Section 112 (b) (5) of the Internal Revenue... | |
 | United States, Walter Elbert Barton - Gifts - 1944 - 1286 pages
...are in control of the corporation to which the assets are transferred, or (E) a recapitalization, or (F) a mere change in identity, form, or place of organization, however effected. verted, or in the acquisition of control of a corporation owning such other property, or in the establishment... | |
 | United States. Congress. Internal Revenue Taxation Joint Committee - 1945 - 350 pages
...are in control of the corporation to which the assets are transferred, or (E) a recapitalization, or (F) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization" includes a corporation resulting from a reorganization and... | |
 | Administrative law - 1975 - 324 pages
...immediately before the transfer), or any combination thereof, is in control of the corporation to which the assets are transferred; but only if, in pursuance...in a transaction which qualifies under section 354, 855, or 359; (E) A recapitalization; or (F) A mere change in identity, form, or place of organization,... | |
 | Administrative law - 1969 - 268 pages
...Immediately before the transfer), or any combination thereof, Is hi control of the corporation to which the assets are transferred; but only If, in pursuance...distributed in a transaction which qualifies under section 364, 856, or 356; (E) A recapitalization; or (F) A mere change In identity, form, or place of organization,... | |
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