 | United States. Tax Court - Taxation - 1959 - 1470 pages
...the preferred stock of the corporation. Section 115 (b) of the Internal Revenue Code of 1939 provides that "every distribution is made out of earnings or...thereof and from the most recently accumulated earnings and profits." At the time of each redemption the corporation had earnings and profits available for... | |
 | United States. Tax Court - Taxation - 1943 - 1330 pages
...without regard to the amount of the earnings and profits at the time the distribution was made. tion is made out of earnings or profits to the extent thereof...the most recently accumulated earnings or profits. The respondent's argument, on the other hand, is that the distribution falls squarely within the definition... | |
 | Administrative law - 1971 - 616 pages
...thereunder. For allocation of earnings and profits in certain corporate separations see section 312(i) and § 1.312-10. (b) The general rule provided in section...transaction subject to section 355, to its shareholders — (1) Of stock or securities in such corporation or in another corporation a party to the reorganization... | |
 | Administrative law - 1976 - 326 pages
...thereunder. For allocation of earnings and profits In certain corporate separations see section 312(1) and f 1.312-10. (b) The general rule provided in section...and from the most recently accumulated earnings or profila aoes not apply to: (1) The distribution, in pursuance of a plan of reorganization, by or on... | |
 | Administrative law - 1949 - 774 pages
...distributions in general, (a) For the purpose of income taxation every distribution made by a corporation is made out of earnings or profits to the extent thereof...the most recently accumulated earnings or profits. In determining the source of a distribution, consideration should be given first, to the earnings or... | |
 | Administrative law - 1984 - 316 pages
...thereunder. For allocation of earnings and profits in certain corporate separations see section 312U) and § 1.312-10. (b) The general rule provided in section...accumulated earnings or profits does not apply to: (l) The distribution, in pursuance of a plan of reorganization, by or on behalf of a corporation a... | |
 | United States - Session laws - 1939 - 780 pages
...the time the distribution was made. (b) SOURCE OF DISTRIBUTIONS. — For the purposes of this chapter every distribution is made out of earnings or profits...the most recently accumulated earnings or profits. Any earnings or profits accumulated, or increase in value of property accrued, before March 1, 1913,... | |
 | Administrative law - 1956 - 786 pages
...liquidation. No allocation of earnings and profits from Corporation A to Corporation B shall be made. (b) The general rule provided in section 316 that...transaction subject to section 355, to its shareholders — (1) Of stock or securities in such corporation or in another corporation a party to the reorganization... | |
 | Administrative law - 1959 - 1338 pages
...liquidation. No allocation of earnings and profits from Corporation A to Corporation B shall be made. d to the stock for purposes of the reorganization....same price one share of the surviving company for e — (1) Of stock or securities in such corporation or in another corporation a party to the reorganization... | |
 | Administrative law - 1970 - 280 pages
...312(1) and § 1.312-10. (b) The general rule provided in section 316 that every distribution is rnadu out of earnings or profits to the extent thereof and...reorganization, by or on behalf of a corporation a party to the reorganisation, or in a transaction subject to section 355, to its shareholders — (1) Of stock or... | |
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... (b) Source of distributions. For the purposes of this Act every distribution is made out of earnings or profits to the extent thereof, and from the most recently accumulated earnings or profits. 
