Buy custom Tax Section 311 Taxability of a Corporation on Dividends
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Business
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4 / 862 |
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311(d) was equal to the FMV of the property distributed to its shareholders under IRC Sec. 301. Pope & Talbot then asserted that the inviolability of the equality principle was demonstrated by the "symmetrical" nature of IRC Secs. 301, 311, and 1001. Pope & Talbot concluded that the term FMV was identical for purposes of IRC Secs...
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301, 311, and 1001. Pope & Talbot concluded that the term FMV was identical for purposes of IRC Secs. 301, 311, and 1001.
The IRS also moved for summary adjudication, requesting an order finding that Pope & Talbot's gain on the distribution of the timber and resort properties was to be determined as if Pope & Talbot had sold its interest in those properties at FMV on the date of distribution...
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