 No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...  Reports of the United States Tax Court - Page 502by United States. Tax Court - 1970Full view - About this book
 | United States. Internal Revenue Service - Internal revenue - 1981 - 808 pages
...and Z. LAW AND ANALYSIS Section 351 of the Code provides that no gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control of the... | |
 | United States. Tax Court - Taxation - 1980 - 1358 pages
...corporation (including, in the case of transfers made on or before June 30, 1967, an investment company) by one or more persons solely in exchange for stock or securities in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c))... | |
 | United States. Tax Court - Law reports, digests, etc - 1950 - 1992 pages
...••••*• (b) (4) No gain or loss shall be recognised if property is transferred to a corporation •7 one or more persons solely in exchange for stock or securities In such corporation, and tamtdiately after the exchange such person or persons are In control of the corporation ; kit in... | |
 | United States. Tax Court - Law reports, digests, etc - 1968 - 1080 pages
...TRANSFEROR. (a) GENERAL RULE. — No gain or loss shall be recognized If property Is transferred to i corporation • • * by one or more persons solely In exchange for stock or securities In Wch corporation and Immediately after the exchange such person or persons are In control (as denned... | |
 | Administrative law - 1970 - 282 pages
...corporation (including, in the case of transfers made on or before June 30, 1967, an investment company) by one or more persons solely in exchange for stock or securities in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c)... | |
 | United States. Tax Court - Taxation - 1971 - 1242 pages
...basis on its tax return for 1965. 2. Section 351. — Petitioners contend that the sale of their WIP shares to CAM falls within the scope of section 351..."security," and we think it is not. See Warren H. Brmvn, 27 TC 27 (1056). For the same reason, we think that petitioners did not do "exactly what Mr.... | |
 | United States. Tax Court - Government publications - 1989 - 1448 pages
...falling within section 351. Section 351 (a) provides that no gain or loss shall be recognized if (1) property is transferred to a corporation by one or...persons solely in exchange for stock or securities in that corporation and (2) immediately after the exchange the transferors of the property are in control... | |
 | United States. Congress. Senate. Foreign Relations - 1971 - 186 pages
...Revenue Code. Section 351 provides that no gain or loss shall be recognized if property is transfererd to a corporation by one or more persons solely in...exchange for stock or securities in such corporation and immediately after the exchange such person or persons owns stock possessing at least 80% of the... | |
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