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acquiring corporation activities adjusted basis adoption allocable amount applies assets basis beginning capital carried carryovers cash class of stock Code common stock computed considered constructive controlled conversion Corporation's date of distribution December 31 depreciation described determined distribution or transfer dividend earnings and profits effect election ending Example exceeds excess exchange facts fair market value filed gain or loss graph hands held holders illustrated increase individual interest issued January Less liabilities limitation liquidation meaning net operating loss outstanding paragraph percent period personal holding poration postacquisition preferred stock purchase pursuant qualified ration realized reason received recognized redemption regard relating reorganization requirements respect result rules ryovers section 301 securities shareholder shares shares of stock stock of Corporation stock or securities subparagraph subsection taxable income term tion trade or business transaction transfer treated tribution
45. lappuse - ... more than 50 percent in value of the outstanding stock of which is owned by the same person. (2) Control. For purposes of this paragraph, control means the ownership of stock possessing at least 50 percent of the total combined voting power of all classes of stock entitled to vote or at least 50 percent of the total value of shares of all classes of stock of the corporation.
27. lappuse - February 28, 1913, or (2) out of its earnings and profits of the taxable year (computed as of the close of the taxable year without diminution by reason of any distributions made during the taxable year), without regard to the amount of the earnings and profits at the time the distribution was made.
27. lappuse - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
35. lappuse - ... at least 80 percent of the total combined voting power of all classes of stock entitled to vote and the owner of at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
85. lappuse - ... such corporation has not continued to carry on a trade or business substantially the same as that conducted before...
67. lappuse - Permanent records in substantial form shall be kept by every taxpayer who participates in a tax-free exchange in connection with a corporate reorganization showing the cost or other basis of the transferred property and the amount of stock or securities and other property or money received (including any liabilities assumed...
51. lappuse - ... trade or business was not acquired by the corporation within such period in a transaction in which gain or loss was recognized in whole or in part.
75. lappuse - ... expended in the acquisition of other property similar or related in service or use to the property so converted, or in the acquisition of control of a corporation owning such other property, or in the establishment of a replacement fund. That section also provides that, if any part of the money is not so expended, the gain, if any, shall be recognized to the extent of the money which is not so expended.
27. lappuse - ... party to the reorganization, stock or securities in such corporation or in another corporation a party to the reorganization, without the surrender by such shareholder of stock or securities in such a corporation, no gain to the distributee from the receipt of such stock or securities shall be recognized.