 | United States. Tax Court - 1985 - 1410 lapas
..."corporation" for tax purposes unless the taxpayer establishes to respondent's satisfaction that the exchange is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes. Because corporate status is essential to nonrecognition treatment under sections 351 and 368(a)(l),... | |
 | United States. Tax Court - 1970 - 1228 lapas
...exchange, It has been established to the satisfaction of the Secretary or his delegate that such exchange is not In pursuance of a plan having as one of its...principal purposes the avoidance of Federal Income taxes. • • • Petitioner at trial and on brief did not argue that respondent's alternative contention... | |
 | 1973 - 882 lapas
...inclusive; or (2) If before the transfer it has been established to the satisfaction of the Commissioner that the transfer is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. (b) Whether a transfer of stock or securities is in pursuance of a plan having as one of its principal... | |
 | United States. Congress. House. Committee on Ways and Means - 1973 - 524 lapas
...of these provisions unless the taxpayer obtains a Treasury ruling prior thereto that the "exchange is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes." Our principal objections to Section 367 in its present form are two-fold : we believe the requirement... | |
 | United States. Congress. House. Committee on Ways and Means - 1975 - 838 lapas
...such transfer, it has been established to the satisfaction of the Secretary or his delegate that such transfer is not in pursuance of a plan having as one...principal purposes the avoidance of federal income taxes. Notwithstanding the similarity of purpose and structure of these sections, Section 1494(b) provides... | |
 | United States. Congress. House. Committee on Ways and Means - 1975 - 348 lapas
...of these provisions unless the taxpayer obtains a Treasury ruling prior thereto that the "exchange is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes. " We believe the requirement that a ruling be obtained before the event should be eliminated in all... | |
 | United States. Congress. House. Committee on Ways and Means - 1975 - 914 lapas
...benefits of these provisions unless the taxpayer obtains a Treasury ruling prior thereto that the "exhange is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal Income taxes." We beiieve the requirement that a ruling be obtained before the event should be eliminated in all circumstances... | |
 | 1966 - 468 lapas
...inclusive; or (2) If before the transfer it has been established to the satisfaction of the Commissioner that the transfer is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. (b) Whether a transfer of stock or securities is in pursuance of a plan having as one of its principal... | |
 | 1949 - 430 lapas
...1932 ; or (2) If prior to the transfer it has been established to the satisfaction of the Commissioner that the transfer is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. (c) Whether a transfer of stock or securities is in pursuance of a plan having as one of its principal... | |
 | 1970 - 772 lapas
...inclusive; or (2) If before the transfer it has been established to the satisfaction of the Commissioner that the transfer is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. (b) Whether a transfer of stock or securities is in pursuance of a plan having as one of its principal... | |
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If before the transfer it has been established to the satisfaction of the Commissioner that the transfer is not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes. 
