 No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...  Reports of the Tax Court of the United States - 234. lappuseautors: United States. Tax Court - 1963Pilnskats - Par šo grāmatu
 | United States. Tax Court - 1989 - 1448 lapas
...falling within section 351. Section 351 (a) provides that no gain or loss shall be recognized if (1) property is transferred to a corporation by one or...persons solely in exchange for stock or securities in that corporation and (2) immediately after the exchange the transferors of the property are in control... | |
 | United States. Congress. House. Committee on Ways and Means - 1971 - 324 lapas
...Funds, investors' stock "is transferred to a corporation [the Fund} . . . in exchange for stock . . . in such corporation and immediately after the exchange such person or persons [investors] are in control . . . of the corporation". The issue, therefore, really is, why should the... | |
 | 1973 - 310 lapas
...corporation (Including, In the case of transfers made on or before June 30, 1967, an Investment company) b; one or more persons solely In exchange for stock or...the exchange such person or persons are In control (as defined In section 3C8(c) ) of the corporation. For purposes of this section, stock or securities... | |
 | 1973 - 288 lapas
...made on or before June 30, 1967, an Investment company) by one or more persons solely In excbange fot stock or securities In such corporation and Immediately...the exchange such person or persons are In control (as defined In section 368(c) ) oí the corporation. For pur- i poses of this section, stock or securities... | |
 | United States. Congress. House. Committee on Ways and Means - 1973 - 432 lapas
...Funds, investors' stock "is transferred to a corporation [the Fund] . . . in exchange for stock . . . in such corporation and immediately after the exchange, such person or persons [the investors] are in control . . . of the corporation". The issue, therefore, really is, why should... | |
 | United States. Commission on Revision of the Federal Court Appellate System - 1975 - 288 lapas
...351 nonrecognition transaction." Under section 351 of the Internal Revenue Code, gain or loss is not recognized "if property is transferred to a corporation...or persons are in control ... of the corporation." The Commissioner argued that under the "tax benefit" rule the transfer of 7395 S. Ct. 171, granting... | |
 | 1968 - 268 lapas
...corporation (including, in the case of transfers made on or before June 30, 1967, an investment company) by one or more persons solely in exchange for stock...the exchange such person or persons are in control (as defined in section 368(c)) of the corporation. For purposes of this section, stock or securities... | |
 | United States. Internal Revenue Service - 1955 - 656 lapas
...exchange common stock in one corporation for common stock in another corporation. PROPERTY FOR STOCK. If property is transferred to a corporation by one...exchange for stock or securities in such corporation and such person or persons immediately after the exchange are in control of the corporation to which the... | |
 | United States. Internal Revenue Service - 1975 - 196 lapas
...transferred to a corporation by one or more persons solely in exchange for stock or securities in that corporation and immediately after the exchange such person or persons are in control p1 the corporation to which the property was transferred, ordinarily no gain or loss will be recognized.... | |
 | United States. Internal Revenue Service - 1976 - 196 lapas
...transferred to a corporation by one or more persons solely in exchange for stock or securities in that corporation and immediately after the exchange such person or persons are in confroYof the corporation to which the property was transferred, ordinarily no gain or loss will be... | |
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