 | United States. Court of Claims, Audrey Bernhardt - 1959 - 1028 páginas
...shall be recognized, except as hereinafter provided In this section. "(b) Exchanges solely In kind — "(5) Transfer to corporation controlled by transferor....In the case of an exchange by two or more persons I Ms paragraph shall apply only If the amount of the stock and securities received by each is substantially... | |
 | United States. Court of Claims, Audrey Bernhardt - 1955 - 928 páginas
...non-recognition of gain or loss under section 112 (b) (5) of the Revenue Act of 1928. This section provides : No gain or loss shall be recognized if property is transferred...exchange for stock or securities in such corporation, * * * [Emphasis supplied.] In order for plaintiffs to come within this section they must show that... | |
 | Harrison B. Spaulding - 1927 - 336 páginas
...corporation is exchanged solely for preferred stock in the same corporation.1 (3) No gain or loss is recognized if property is transferred to a corporation...the exchange such person or persons are in control (that is, have the ownership of at least 80 % of the voting 1 See Revenue Act of 1924, Section 208.... | |
 | Robert Hiester Montgomery - 1925 - 1928 páginas
...Exchange of property for securities of a controlled corporation. — LAW. Section 203 (b) .... (4) No gain or loss shall be recognized if property is transferred...person or persons are in control of the corporation; *5 but in the case of an exchange by two or more persons this paragraph shall apply only if the amount... | |
 | United States. Board of Tax Appeals - 1930 - 1554 páginas
...type of transaction referred to in section 203 (b) (4) of the Revenue Act of 1924 is that in which property is transferred to a corporation by one or...person or persons are in control of the corporation. Section 202 (c) of the Revenue Act of 1921 provides: For the purposes of this title, on an exchange... | |
 | United States. Board of Tax Appeals - 1934 - 1646 páginas
...BTA 1273 ; Katherine A. Spalding, 7 BTA 588 ; BF Saul, 4 BTA 639 : EH Nielsen Co., 26 BTA 223. 1 No gain or loss shall be recognized If property Is transferred...exchange for stock or securities In such corporation, and Imnn^diately after the exchange such person or persons are in control of the corporation ; bat in the... | |
 | United States. Board of Tax Appeals - 1935 - 1394 páginas
...section 202, shall be recognized, except as hereinafter provided in this section. ******* (b)(4) No gain or loss shall be recognized if property is transferred...corporation ; but in the case of an exchange by .two nr more persons this paragraph shall apply only if the amount of the stock and securities received... | |
 | United States. Board of Tax Appeals - 1937 - 1380 páginas
...existed in the earlier law.8 1 RECOGNITION OF GAIN OR LOSS FROM SALES AND EXCHANGES. SBC. 203. (b) (4) No gain or loss shall be recognized if property Is transferred...Immediately after the exchange such person or persons nre in control of the corporation ; but in the case of an exchange by two or more persons this paragraph... | |
 | United States. Board of Tax Appeals - 1939 - 1702 páginas
...TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. — No gain or loss shall be recognized If property la transferred to a corporation by one or more persons...Immediately after the exchange such person or persons arc In control of the corporation ; but In the case of an exchange hy two or more persons this paragraph... | |
 | United States - 1965 - 1110 páginas
...controlled by transferor. §351. Transfer to corporation controlled by transferor. (a) General rule. No gain or loss shall be recognized if property is transferred...the exchange such person or persons are in control (as defined in section 368 (c) ) of the corporation. For purposes of tMs 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... 
