It is the purpose of this discussion to indicate, with respect to corporate accumulations and distributions, some of the major interpretative problems existing under the 1939 code which Congress has failed to resolve, as well as some of the major interpretative difficulties which arise for the first time under the 1954 code
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
From 1921 to 1929, appellee corporation bought shares of its own stock, not for retirement, but to s...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
Federal income taxation of stock dividends has followed a diverse course. Since the introduction of ...
This comment will not be expository of all of the trust provisions but rather will attempt to deal w...
Section 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorga...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
On December 10, 1969, the most massive and controversial piece of tax legislation ever proposed was ...
Stock and securities of controlled corporations may be distributed to shareholders, tax free, in cas...
Prior to 1939 whenever a corporation paid less than the face amount of an obligation in full satisfa...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
From 1921 to 1929, appellee corporation bought shares of its own stock, not for retirement, but to s...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
Federal income taxation of stock dividends has followed a diverse course. Since the introduction of ...
This comment will not be expository of all of the trust provisions but rather will attempt to deal w...
Section 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorga...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
On December 10, 1969, the most massive and controversial piece of tax legislation ever proposed was ...
Stock and securities of controlled corporations may be distributed to shareholders, tax free, in cas...
Prior to 1939 whenever a corporation paid less than the face amount of an obligation in full satisfa...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
From 1921 to 1929, appellee corporation bought shares of its own stock, not for retirement, but to s...