Add to ORKGMr. Ellis examines the tax consequences arising when a taxpayer sells appreciated property to a controlled corporation in order to realize a capital gain for himself as well as to increase the basis of the property. He points out the dangers inherent in such a transaction and suggests precautions which should be taken to obtain favorable tax treatment. The author concludes that a taxpayer transferring appreciated property to a controlled corporation may achieve substantial tax benefits because of the relative ineffectiveness of sections 351 and 1239; however, it will be almost impossible for a taxpayer to recognize a loss on the transfer of depreciated property because of section 267
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
Investors in depreciable assets used in a trade or business claim depreciation deductions following ...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
This Note argues that although the Tennessee-Carolina majority adopts overbroad language and ignores...
A corporate promoter entered into an earnest money agreement which contemplated corporate purchase o...
Inadequacies of the statutory definition of capital asset have led the courts to develop the conce...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
The taxpayer purchased A Company stock from X for $100,000 and later sold it for $7,500, deducting t...
A corporate promoter entered into an earnest money agreement which contemplated corporate purchase o...
A corporate promoter entered into an earnest money agreement which contemplated corporate purchase o...
This Comment examines the recent development of tax strategies by which a homeowner, desiring to sel...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
Investors in depreciable assets used in a trade or business claim depreciation deductions following ...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
This Note argues that although the Tennessee-Carolina majority adopts overbroad language and ignores...
A corporate promoter entered into an earnest money agreement which contemplated corporate purchase o...
Inadequacies of the statutory definition of capital asset have led the courts to develop the conce...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
The taxpayer purchased A Company stock from X for $100,000 and later sold it for $7,500, deducting t...
A corporate promoter entered into an earnest money agreement which contemplated corporate purchase o...
A corporate promoter entered into an earnest money agreement which contemplated corporate purchase o...
This Comment examines the recent development of tax strategies by which a homeowner, desiring to sel...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
Investors in depreciable assets used in a trade or business claim depreciation deductions following ...