§1064

96 (Ohio Ct. App. 1929) ("Ifthere is liquidation ofa corporation, partial or complete, the determining element ofthe transaction is whether the stockholders surrender and cancel the stock which is given in exchange[.]"); 18B Am. Jur. 2d Corporations sec. 1064 (noting that share- holders' right to receive accumulated dividends on liquidation applies identically in partial and complete liquidations). - 55 - [*55] "debt collection" business. There is no evidence that it made any effort to collect t

* * subject to the provisions of section 1064 of the Taxpayer Relie f Act of 1997 ." Petitioners contend that the relevant item is interest, including OID, and by using t at description COB obtained consent to change its treatmen, of late-fee income, a "component" of interest, including OID .