Tax Research
Tax Research Exercise 1
1) 147(c)(2)(C)(iii)Insolvent farmer.—For purposes of clause (i), farmland which was previously owned by the individual and was disposed of while such individual was insolvent shall be disregarded if section 108 applied to indebtedness with respect to such farmland.
2) Federal Tax Regulations, Regulation, §1.351-1., Internal Revenue Service, Transfer to corporation controlled by transferor Click to open document in a browser
Reg. § 1.351-1 does not reflect P.L. 96–589, P.L. 100-647 or P.L. 101-239.
(a)
(1) Section 351(a) provides, in general, for the nonrecognition of gain or loss upon the transfer by one or more persons of property to a corporation solely in exchange for stock or securities in such corporation if, immediately after the exchange, such person or persons are in control of the corporation to which the property was transferred. As used in section 351, the phrase "one or more persons" includes individuals, trusts, estates, partnerships, associations, companies, or corporations (see section 7701(a)(1)). To be in control of the transferee corporation, such person or persons must own immediately after the transfer stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 per cent of the total number of shares of all other classes of stock of such corporation (see section 368(c)). In determining control under this section, the fact that any corporate transferor distributes part or all of the stock which it receives in the exchange to its shareholders shall not be taken into account. The phrase "immediately after the exchange" does not necessarily require simultaneous exchanges by two or more persons, but comprehends a situation where the rights of the parties have been previously defined and the execution of the agreement proceeds with an expedition consistent with orderly procedure. For purposes of this section— (i) stock or
1) 147(c)(2)(C)(iii)Insolvent farmer.—For purposes of clause (i), farmland which was previously owned by the individual and was disposed of while such individual was insolvent shall be disregarded if section 108 applied to indebtedness with respect to such farmland.
2) Federal Tax Regulations, Regulation, §1.351-1., Internal Revenue Service, Transfer to corporation controlled by transferor Click to open document in a browser
Reg. § 1.351-1 does not reflect P.L. 96–589, P.L. 100-647 or P.L. 101-239.
(a)
(1) Section 351(a) provides, in general, for the nonrecognition of gain or loss upon the transfer by one or more persons of property to a corporation solely in exchange for stock or securities in such corporation if, immediately after the exchange, such person or persons are in control of the corporation to which the property was transferred. As used in section 351, the phrase "one or more persons" includes individuals, trusts, estates, partnerships, associations, companies, or corporations (see section 7701(a)(1)). To be in control of the transferee corporation, such person or persons must own immediately after the transfer stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 per cent of the total number of shares of all other classes of stock of such corporation (see section 368(c)). In determining control under this section, the fact that any corporate transferor distributes part or all of the stock which it receives in the exchange to its shareholders shall not be taken into account. The phrase "immediately after the exchange" does not necessarily require simultaneous exchanges by two or more persons, but comprehends a situation where the rights of the parties have been previously defined and the execution of the agreement proceeds with an expedition consistent with orderly procedure. For purposes of this section— (i) stock or
References: 4. Ross Pierce prepared the original letter calling a meeting held in Sacramento, California on September 3, 1907, which meeting was the beginning of the California Land Title Association. 9. Plaintiff is a California corporation formed March 31, 1925 and has its principal office in Placerville, El Dorado County, California. The company acquired the assets of the Pierce-Bosquit Abstract and Title Co. for Nevada and El Dorado Counties. U.S. Tax Court, Docket No. 6886-80, 43 TCM 1481, TC Memo. 1982-292, Filed May 26, 1982 [Appealable, barring stipulation to the contrary, to CA-6.—CCH] [Code Sec 11) U.S. Master Tax Guide (2013), 1195. Hobby Expenses and Losses Click to open document in a browser 12) Standard Federal Tax Reporter (2013), 14,417.043, Substantiation Requirements and Per Diem Rates: Standard Mileage Rate Allowances for Automobiles: Standard mileage rate allowances for automobiles, in general Click to open document in a browser