 | United States. Tax Court - 1975 - 1272 páginas
...$91,000.00 more over the 14 yrs. than Milo E. Wilson. OPINION Section 351 provides, in part, that no gain shall be recognized if property is transferred to...the exchange such person or persons are in control of the corporation. 2 "Control" is defined for this purpose in section 368(c) as ownership of stock... | |
 | United States. Tax Court - 1974 - 936 páginas
...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...person or persons are In control (as defined In section 3C8(c)) of the corporation. • • • • The record does not state specifically that the partnerships... | |
 | 1971 - 616 páginas
...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...exchange such person or persons are In control (as denned In section 368(c) ) of the corporation. For purposes of this section, stock or securities Issued... | |
 | United States. Congress. House. Committee on Ways and Means - 1971 - 324 páginas
...Funds, investors' stock "is transferred to a corporation [the Fund} . . . in exchange for stock . . . in such corporation and immediately after the exchange such person or persons [investors] are in control . . . of the corporation". The issue, therefore, really is, why should the... | |
 | United States. Tax Court - 1970 - 1228 páginas
...June 30, 1987, u Investment company) by one or more persons solely In exchange for stock or securltlj* In such corporation and Immediately after the exchange such person or persons an In control (as defined In section 368(c)) of the corporation. For purposes of this section, stock... | |
 | United States. Tax Court - 1971 - 1470 páginas
...a corporation by one or more persons solely in exchange for stock or securities in such conwration. and Immediately after the exchange such person or persons are in control of the corporation; but in the case of an exchange by tiro or more persons this paragraph shall apply... | |
 | 1973 - 310 páginas
...corporation (Including, In the case of transfers made on or before June 30, 1967, an Investment company) b; one or more persons solely In exchange for stock or...person or persons are In control (as defined In section 3C8(c) ) of the corporation. For purposes of this section, stock or securities issued for services... | |
 | 1973 - 288 páginas
...made on or before June 30, 1967, an Investment company) by one or more persons solely In excbange fot stock or securities In such corporation and Immediately...persons are In control (as defined In section 368(c) ) oí the corporation. For pur- i poses of this section, stock or securities Issued for services snail... | |
 | United States. Congress. House. Committee on Ways and Means - 1973 - 432 páginas
...Funds, investors' stock "is transferred to a corporation [the Fund] . . . in exchange for stock . . . in such corporation and immediately after the exchange, such person or persons [the investors] are in control . . . of the corporation". The issue, therefore, really is, why should... | |
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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... 
