 ... it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes.  Internal Revenue Cumulative Bulletin - Page 112by United States. Internal Revenue Service - 1977Full view - About this book
 | United States. Internal Revenue Service - Tax administration and procedure - 1964 - 744 pages
...before such exchange, it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. Since section 367 of the Code is intended to prevent the avoidance of Federal income taxes, it necessarily... | |
 | United States. Internal Revenue Service - Tax administration and procedure - 1968 - 938 pages
...before such exchange, it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. For purposes of this section, any distribution described in section 355 (or so much of section 356... | |
 | United States. Internal Revenue Service - Tax administration and procedure - 1964 - 888 pages
...established to the satisfaction of the Secretary of the Treasury or his delegate that the liquidation is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes. Basis of certain property acquired jrom a decedent Paragraph (5) (A) of section 21 6 (j) of the bill... | |
 | United States. Internal Revenue Service - Tax administration and procedure - 1954 - 1182 pages
...corporation unless, prior to such exchange, it has been established to the satisfaction of the Commissioner that such exchange is not in pursuance, of a plan...principal purposes the avoidance of Federal income taxes. Section 39.112(g)-l of Regulations 118 provides in part that under the general rule, upon the exchange... | |
 | United States. Congress. Senate. Committee on Finance - Taxation - 1954 - 662 pages
...transaction it has established to the satisfaction of the Secretary or his delegate that the transaction is not in pursuance of a plan having as one of its...purposes the avoidance of Federal income taxes. The operation of this section is not clear, as is demonstrated by reference to the provisions with respect... | |
 | United States. Congress. Senate. Committee on Finance - Finance, Public - 1954 - 1186 pages
...transaction it has established to the satisfaction of the Secretary or his delegate that the transaction is not in pursuance of a plan having as one of its...purposes the avoidance of Federal income taxes. The operation of this section is not clear, as is demonstrated by reference to the provisions with respect... | |
 | United States. Internal Revenue Service - Tax administration and procedure - 1955 - 1158 pages
...transfer it has been established to the satisfaction of tlie Secretary or bis delegate that such transfer is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes. SEC. 1.1492-1. NONTAXABLE TRANSFERS. — (a) The tax imposed by iction 1491 does not apply: (1) If... | |
 | United States. Congress. House. Committee on Ways and Means - Investments, American - 1959 - 640 pages
...before such exchange, it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. For purposes of this section, any distribution described in section 355 (or so much of section 356... | |
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