 | United States. Tax Court - Law reports, digests, etc - 1950 - 1992 pages
...9.588 64 4.851.10 Ho gain or loss shall be recognized If property is transferred to a corporation bj one or more persons solely in exchange for stock or...person or persons are In control of the corporation; * * * Section 112 (c) (1) provides: If an exchange would be within the provisions of subsection (b)... | |
 | United States. Tax Court - Taxation - 1959 - 1470 pages
...• • • • (B) TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall he recognized If property Is transferred to a corporation...such corporation, and Immediately after the exchange snch person or persons are In control of the corporation ; but In the case of an exchange by two or... | |
 | United States. Internal Revenue Service - Internal revenue - 1977
...construction business after the transaction. Section 351 (a) of the Code provides that no gain or loss will r purposes of his federal income tax. Griffiths v. Commissioner, if immediately after the exchange the transferors are in control of the corporation as defined in section... | |
 | United States. Internal Revenue Service - Internal revenue - 1975 - 804 pages
...realized by У on the transfer. Section 351 (a) of the Code provides, in part, that no gain or loss will be recognized if property is transferred to a corporation...exchange for stock or securities in such corporation if immediately after the exchange such person or persons are in control (as defined in section 368... | |
 | United States. Internal Revenue Service - Internal revenue - 1981 - 808 pages
...in a partnership composed of S, Y, and Z. LAW AND ANALYSIS Section 351 of the Code provides that no gain or loss shall be recognized if property is transferred...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 - 1956 - 1226 pages
...of book value had been transferred to the corpora1 Section 112 (b) (5) provides that "No gain or Ion shall be recognized If property Is transferred to...persons solely In exchange for stock or securities In Buch corporation, and Immediately after the exchange inch person or persons are In control of the corporation... | |
 | United States. Tax Court - Taxation - 1949 - 1378 pages
...RECOGNITION OF GAIN OR LOSS. • ••••• (b) • . • (5> TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR.— No gain or loss shall be recognized...transferred to a corporation by one or more persons solely ID 'change for stock or securities In such corporation, and Immediately after the exchange c" Person... | |
 | United States. Tax Court - Taxation - 1980 - 1358 pages
...that analysis in future cases. Section 351 specifically provides for nonrecognition of gain or loss "if property is transferred to a corporation by one...exchange for stock or securities in such corporation. " (Emphasis added.) See Marcher v. Commissioner, 32 BTA 76, 79 (1935). Compare Helvering v. Bashford,... | |
 | United States. Tax Court - Law reports, digests, etc - 1950 - 1678 pages
...CORPORATION CONTROLLED BY TRANSFEROR.—No gain or loss shall be recognized If property Is transferred to n corporation by one or more persons solely In exchange...such corporation, and Immediately after the exchange •nch person or persons are In control of the corporation ; but In the case of an exchange by two... | |
 | 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...the exchange such person or persons are in control (as defined in section 368(c) ) of the corporation. For purposes of this section, stock or securities... | |
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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... 
