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Under section 351, a person transferring property to a controlled corporation generally recognizes no gain or loss on the transaction. An exception to tax-free treatment is contained in section 357(c), which generally provides that a transferor in a section 351 transaction recognizes gain to the extent that any liabilities assumed by the corporation on the transfer exceed the transferor\u27s aggregate adjusted basis in the assets transferred. An issue under section 357(c) is whether the recognized gain should be capital gain or ordinary income. The statute suggests that the character of section 357(c) gain should be based on the character of the transferred assets, but this does not provide a clear answer when two or more assets of differin...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
Under section 351, a person transferring property to a controlled corporation generally recognizes n...
Incorporation of an existing business almost invariably raises the question of whether the corporati...
Internal Revenue Code section 351(a) provides that no gain or loss shall be recognized if property i...
D. B. Anders was the sole stockholder of D. B. Anders, Inc., an industrial service concern which ren...
In Bongiovanni v. Commissioner, the Second Circuit Court of Appeals applied a new interpretation of ...
Mr. Ellis examines the tax consequences arising when a taxpayer sells appreciated property to a cont...
This Note argues that although the Tennessee-Carolina majority adopts overbroad language and ignores...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
To combat a relatively arcane international tax-shelter abuse, Congress recently amended Code sectio...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
The taxpayer’s method of property acquisition is significant in determining the proper income tax or...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
Under section 351, a person transferring property to a controlled corporation generally recognizes n...
Incorporation of an existing business almost invariably raises the question of whether the corporati...
Internal Revenue Code section 351(a) provides that no gain or loss shall be recognized if property i...
D. B. Anders was the sole stockholder of D. B. Anders, Inc., an industrial service concern which ren...
In Bongiovanni v. Commissioner, the Second Circuit Court of Appeals applied a new interpretation of ...
Mr. Ellis examines the tax consequences arising when a taxpayer sells appreciated property to a cont...
This Note argues that although the Tennessee-Carolina majority adopts overbroad language and ignores...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
To combat a relatively arcane international tax-shelter abuse, Congress recently amended Code sectio...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
The taxpayer’s method of property acquisition is significant in determining the proper income tax or...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
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