 | United States. Tax Court - Taxation - 1975 - 1272 pages
...corporation controlled by transferor) applies, or (2) as paid-in surplus or as a contribution to capital, then the basis shall be the same as it would be in...of the transferor, increased in the amount of gain recognized to the transferor on such transfer. * Petitioner would also benefit from increased net operating... | |
 | United States. Tax Court - Law reports, digests, etc - 1959 - 1456 pages
...surplus or as a contribution to capital, then the basis shall be the lame as it would be In the bands of the transferor. Increased in the amount of gain...in the amount of loss recognized to the transferor npon such transfer under the law applicable to the year in which the transfer wai mad*. stead of $250,000... | |
 | United States. Tax Court - Taxation - 1949 - 1378 pages
...— (B) as paid-in surplus or as a contribution to capital, then tbe basis shall be the same It would be In the hands of the transferor, Increased In the amount of gain or decreased I the amount of loss recognized to the transferor upon such transfer under the law applicable... | |
 | United States. Internal Revenue Service - Internal revenue - 1973
..."(B) as paid-in surplus or aa a contribution to capital, then the basis shall he tbe same aa it would be in the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognised to the transferor upon such transfer under the law applicable... | |
 | United States. Internal Revenue Service - Tax administration and procedure - 1979 - 664 pages
...applies, section 362 (a) (1) requires that the basis of the assets acquired be the same as they would be in the hands of the transferor, increased in the amount of gain recognized to the transferor on such transfer. Section 472 (a) of the Code allows a taxpayer to elect... | |
 | United States. Internal Revenue Service - Internal revenue - 1974 - 624 pages
...basis to a corporation of property acquired in a section 351 transaction will be the same as it would be in the hands of the transferor, increased in the amount of gain recognized to the transferor on such transfer. Pursuant to section 1.1032-l(d) of the regulations,... | |
 | United States. Internal Revenue Service - Internal revenue - 1975 - 652 pages
...basis of property acquired in a transaction to which section 351 applies will be the same as it would be in the hands of the transferor, increased in the amount of gain recognized to the transferor on such transfer. Section 1031 (a) of the Code provides, in part, that... | |
 | Administrative law - 1971 - 1766 pages
...property to the corporation consisted of property or money in addition to such stock or securities) , then the basis shall be the same as it would be in...the transferor, increased in the amount of gain or deceased in the amount of loss recognized to the transferor on such transfer under the law applicable... | |
 | United States. Tax Court - Taxation - 1970 - 1228 pages
...corporation controlled by transferor) applies, or (2) as paid-in surplus or as a contribution to capital, then the basis shall be the same as it would be in...of the transferor, increased in the amount of gain recognized to the transferor on such transfer. The Aldennans incurred no cost in making the note, so... | |
 | United States. Tax Court - Government publications - 1985 - 1410 pages
...property was acquired by a corporation in connection with a reorganization to which this part applies, then the basis shall be the same as it would be in...of the transferor, increased in the amount of gain recognized to the transferor on such transfer. This subsection shall not apply if the property acquired... | |
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... (B) as paid-in surplus or as a contribution to capital, then the basis shall be the same as it would be in the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer... 
