Federal Income Taxation Of Corporations And Stockholders In A Nutshell

Author: Karen C. Burke
Publisher: West Group
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Karen C. Burke. Eisner v. Macomber, 252 U.S. 189, 40 S.Ct. 189, 64 L.Ed. 521 (
1920), 144 Esmark, Inc. v. Commissioner, 90 T.C. 171 (1988), aff d without
published opinion 886 F.2d 1318 (7th Cir.1989), 17 Estate of (see name of party)
Federated Dept. Stores, Inc., In re, 94-2 USTC 1150,430 (S.D.Ohio 1994), 227
Fink, Commissioner v., 483 U.S. 89, 107 S.Ct. 2729, 97 L.Ed.2d 74 (1987), 77,
157 Fireoved v. United States, 462 F.2d 1281 (3rd Cir.1972), 165 First State Bank
of Stratford, ...

Federal Income Taxation Of Corporations And Stockholders In A Nutshell

Author: Jonathan Sobeloff
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Cf. Rev.Rul. 77-245 (stockholders presented certificates for notation thereon of
amount distributed). I.R.S. may be the party seeking to waive the redemption
requirement where the distributee is a corporation. See Fowler Hosiery, Inc. (T.C.
1961 affd 7th Cir. 1962). Note that caution therefore must be exercised before
distributing a hoped-for dividend in kind eligible for § 243 to corporate
stockholders, if the Service might find a corporate contraction of the distributing
corporation with more ...

Collier On Bankruptcy Taxation

Author: Myron M. Sheinfeld
Publisher: LexisNexis
ISBN: 1579111084
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The continuity of interest analysis in the case is criticized in Bittker & Eustice,
Federal Income Taxation of Corporations and Shareholders 12-42 (WGL 7th ed.
2000). Note, however, that a debt instrument with a term of less than five years
can qualify as a tax security when received in a reorganization in exchange for a
similar debt instrument (albeit with a sufficiently different interest rate that would
cause it to constitute a significant modification under Treas. Reg. § 1.1001-3) with
the ...

Negotiated Acquisitions Of Companies Subsidiaries And Divisions

Author: Lou R. Kling
Publisher: Law Journal Press
ISBN: 9781588520562
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55-59, 1955-1 C.B. 35; Bittker and Eustice, Federal Income Taxation of
Corporations and Shareholders i 12.23 [8] (7th ed. 2002). The Internal Revenue
Service has also ruled that the adoption of a poison pill plan is a tax "nothing"
and stock transferred with pill rights should not disqualify an otherwise valid "B"
reorganization. Rev. Rul. 90-11, 1990-1 C.B. 10; Rizzi, "Poison Pill Ruling Gives
Only a Partial Antidote to Take-Over Uncertainty," 17 J. Corp. Tax'n 262 (1990).
The acquiror can ...

Cases And Materials On Federal Income Taxation Taxation Of Corporations Shareholders Partnerships And Partners

Author: Adrian A. Kragen
Publisher:
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... approximately 1200 pages, 1980 (Casebook) Hagman's Hornbook on Urban
Planning and Land Development Control Law, 706 pages, 1971 (Text) Wright
and Webber's Land Use in a Nutshell, 316 pages, 1978 (Text) See also Housing
and Urban Development LAW AND ECONOMICS Manne's The Economics of
Legal Relationships — Readings in the Theory of Property Rights, 660 pages,
1975 (Text) See also Regulated Industries LAW AND MEDICINE-PSYCHIATRY
King's The ...

Federal Income Taxation Of Corporations And Shareholders

Author: Boris I. Bittker
Publisher: Warren Gorham & Lamont
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for these preliminary capitalized costs.” The line separating abandonment from
mere deferral, however, is easier to announce than to draw.” * 5.05 DIVIDENDS-
RECEIVED DEDUCTIONS AND RELATED PROBLEMS Dividends received by a
corporate taxpayer ordinarily qualify for the dividends-received deduction
provided by § 243 (either 70 percent, 80 percent, or 100 percent of dividends
received from a domestic corporation subject to federal income taxes), § 244 (at
1993 rates, ...

Federal Income Taxation Of Corporations And Shareholders

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1 On the other hand, some favorable corporate tax attributes and benefits have
been held immune to denial under §269, despite the breadth of its provisions;
thus, it has been held that §269 cannot be used to disregard the corporate entity
and tax the corporation's income directly to its shareholders; to disallow the
nonrecognition of income prescribed by §336 for the corporate distribution of
appreciated property (supra 11 11.61 ), the stepped-up basis prescribed by §334
(b) ( 2), or the ...