§10223

3 cases·3 cited

Statute text not available for this section.

3 Citing Cases

’s) subsequent distribution of the subsidiary stock to its shareholders, within the 5-year period, does violate the requirements of sec. 355(b)(2)(D). The prior distribution to P also violates sec. 355(b)(2)(D) as amended by the Revenue Act of 1987, sec. 10223(b), 101 Stat. 1330, supra, and sec. 2004(h)(1) of TAMRA, supra. As a result, Rev. Rul. 89-37, 1989 C.B. 107, obsoletes the holding of Rev. Rul. 74-5, supra, with respect to the distribution to P.

’s) subsequent distribution of the subsidiary stock to its shareholders, within the 5-year period, does violate the requirements of sec. 355(b)(2)(D). The prior distribution to P also violates sec. 355(b)(2)(D) as amended by the Revenue Act of 1987, sec. 10223(b), 101 Stat. 1330, supra, and sec. 2004(h)(1) of TAMRA, supra. As a result, Rev. Rul. 89-37, 1989 C.B. 107, obsoletes the holding of Rev. Rul. 74-5, supra, with respect to the distribution to P.

’s) subsequent distribution of the subsidiary stock to its shareholders, within the 5-year period, does violate the requirements of sec. 355(b)(2)(D). The prior distribution to P also violates sec. 355(b)(2)(D) as amended by the Revenue Act of 1987, sec. 10223(b), 101 Stat. 1330, supra, and sec. 2004(h)(1) of TAMRA, supra. As a result, Rev. Rul. 89-37, 1989 C.B. 107, obsoletes the holding of Rev. Rul. 74-5, supra, with respect to the distribution to P.