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
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Modern dividend statutes, as exemplified by the Model Business Corporation Act, have incorporated ma...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
On December 10, 1969, the most massive and controversial piece of tax legislation ever proposed was ...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
Stock and securities of controlled corporations may be distributed to shareholders, tax free, in cas...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
Federal income taxation of stock dividends has followed a diverse course. Since the introduction of ...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
This comment will not be expository of all of the trust provisions but rather will attempt to deal w...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Modern dividend statutes, as exemplified by the Model Business Corporation Act, have incorporated ma...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
On December 10, 1969, the most massive and controversial piece of tax legislation ever proposed was ...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
Stock and securities of controlled corporations may be distributed to shareholders, tax free, in cas...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
Federal income taxation of stock dividends has followed a diverse course. Since the introduction of ...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
This comment will not be expository of all of the trust provisions but rather will attempt to deal w...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Modern dividend statutes, as exemplified by the Model Business Corporation Act, have incorporated ma...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...