Proceedings of New York University ... Annual Institute on Federal Taxation, Opseg 16

acquired acquisition aff'd affiliated group agreement allocation amount annuity apply assets basis benefits cash claim Comm'r Commissioner compensation consolidated return contribution cost deduction depreciation distributive share dividends earnings election employee entities exemption fair market value filed FSupp gain or loss gift tax held income tax Internal Revenue Code Internal Revenue Service inventory investment Investor joint venture liability lien LIFO limited liquidation ment Old Company operating ordinary income ownership paid parent corporation partner partnership interest payment period poration preferred stock prior problem profits Prop Reg provides purchase purpose qualified real estate realized refund regulations restricted stock result retirement Rev Rul Revenue Ruling rules Section 269 Section 337 selling shareholders statute stock option stockholders substantial supra note syndicate tax avoidance tax consequences Tax Court tax-free taxable income Taxation taxpayer tion trade or business transaction transfer treated trust unrealized receivables