Add to ORKGThe United States Supreme Court in Turnbow v. Commissioner may have interpreted the Internal Revenue Code to preclude the receipt of boot in a non-taxable, stock for stock reorganization. Although the Court was interpreting the application of Section 112 of the 1939 Code, the decision may be decisive in the interpretation of the parallel sections in the 1954 Code
Taxpayer corporation, which had sustained losses in the hardware business, entered into an agreement...
In connection with income taxation, some importance is attached to the difference between mergers an...
This Article reviews the redemption provisions of both section 302 and section 304 of the Internal R...
Acquisitive reorganizations either by consolidation or statutory merger have become a popular means ...
A stock-for-stock reorganization which qualifies under IRC section 368(a)(1)(B) accords tax-free tre...
The recent Supreme Court decision in Le Tulle v. Scofield, disapproving the views of four out of fiv...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
An individual wished to buy certain patents from a corporation, and at his instigation, the corporat...
Petitioner owned more than three-fourths of the stock in a corporation whose shares had a par value ...
It is common today to read of corporations merging or of one corporation buying out another. Man...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Section 368(a)(l)(F) of the Internal Revenue Code (Code) defines the least complex of all corporate ...
If specified conditions are satisfied, the Internal Revenue Code provides nonrecognition for gain or...
Plaintiff held common and preferred stock of the Gulf States Paper Corporation. In 1942 plaintiff re...
Taxpayer corporation, which had sustained losses in the hardware business, entered into an agreement...
In connection with income taxation, some importance is attached to the difference between mergers an...
This Article reviews the redemption provisions of both section 302 and section 304 of the Internal R...
Acquisitive reorganizations either by consolidation or statutory merger have become a popular means ...
A stock-for-stock reorganization which qualifies under IRC section 368(a)(1)(B) accords tax-free tre...
The recent Supreme Court decision in Le Tulle v. Scofield, disapproving the views of four out of fiv...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
An individual wished to buy certain patents from a corporation, and at his instigation, the corporat...
Petitioner owned more than three-fourths of the stock in a corporation whose shares had a par value ...
It is common today to read of corporations merging or of one corporation buying out another. Man...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Section 368(a)(l)(F) of the Internal Revenue Code (Code) defines the least complex of all corporate ...
If specified conditions are satisfied, the Internal Revenue Code provides nonrecognition for gain or...
Plaintiff held common and preferred stock of the Gulf States Paper Corporation. In 1942 plaintiff re...
Taxpayer corporation, which had sustained losses in the hardware business, entered into an agreement...
In connection with income taxation, some importance is attached to the difference between mergers an...
This Article reviews the redemption provisions of both section 302 and section 304 of the Internal R...