§251
41 cases·3 followed·2 questioned·2 criticized·34 cited—7% support
Statute Text — 26 U.S.C. §251
Statute text not available for this section.
41 Citing Cases
Although we are not convinced that, as a matter of law, petitioner's acquisition of the assets of the transferred business was part of an exchange to which section 351 applies, we will treat it as such in disposing of the cases before us.
Although we are not convinced that, as a matter of law, petitioner's acquisition of the assets of the transferred business was part of an exchange to which section 351 applies, we will treat it as such in disposing of the cases before us.
However, we cannot agree that the donees could have been compelled to sell their stock warrants under this provision.
As petitioners suggest, respondent might have cited other provisions of Delaware’s General Corporation Law, including section 251, which deals with the merger of two or more entities into one corporation following a resolution of the board of directors and upon a vote of a majority of the outstanding voting stock, and section 275, which deals with the dissolution of a corporation following a resolution of the board of directors upon a vote of a majority of the out
251.175 (1995). For the election at issue which occurred during 2000, the Oregon secretary ofstate was required to mail the voters pamphlets no less than 20 days before the election. R (1999) (applicable for elections held after January 2, 2000). ¹°A ballot title consisted ofa caption that reasonably identified the subject matter ofthe measure
251.175 (1995). For the election at issue which occurred during 2000, the Oregon secretary ofstate was required to mail the voters pamphlets no less than 20 days before the election. R (1999) (applicable for elections held after January 2, 2000). ¹°A ballot title consisted ofa caption that reasonably identified the subject matter ofthe measure
251.112(a), 110(c), 114(f) (2006). After considering these factors and the Fitzgeralds' claims to a preexisting easement, the Court ofAppeals for the Ninth Circuit rejected the Fitzgeralds' claims. That court concluded that "FLPMA vests the Secretary ofAgriculture with the authority to regulate access over the Sitzgreaves National Forest. 43 U
Thus section 52 governs the manner of filing corporation returns, section 215(a) deals with the manner of filing returns by or for nonresident aliens, section 251(f) the manner of filing returns by citizens of the United States who are in receipt of income from sources within possessions of the United States, and section 233 the manner of filing returns for a foreign corporation.
Thus section 52 governs the manner of filing corporation returns, section 215(a) deals with the manner of filing returns by or for nonresident aliens, section 251(f) the manner of filing returns by citizens of the United States who are in receipt of income from sources within possessions of the United States, and section 233 the manner of filing returns for a foreign corporation.
78 as to a partner's gross income for the purpose of section 251 of the Internal Revenue Code of 1939, provides, and th s Court has recognized, that a partnership return is to be considered together with an individual teturn in determining the total gross income stated in the individual return for the purpose of determining whether the 6-year statute Of limitations is applicable.
78, as to a partner’s gross income for the purpose of section 251 of the Internal Revenue Code of 1939, provides, and this Court has recognized, that a partnership return is to be considered together with an individual return in determining the total gross income stated in the individual return for the purpose of determining whether the 6-year statute of limitations is applicable.
251, 96th Cong., proposing new I.R.C. sec. 44D(3)(3)(A).] Thus, the committee reports, as well as section 29, show that Congress intended the credit to be based on the barrel of - 9 - oil equivalent of fuels produced. 2. Petitioner’s Argument Petitioner contends that, under a literal reading of section 29, S/V is entitled to a double credit f
mount of the taxpayer’s gross income from such property for such year from such sales bears to the aggregate gross income from such property for such year from such sales. [Crude Oil Windfall Profit Tax Act of 1979, H.R. 3919, 96th Cong., 1st Sess., sec. 251 (1979) (proposing new I.R.C. sec. 44D(3)(3)(A)).] Thus, the committee reports, as well as section 29, show that Congress intended the credit to be based on the barrel of oil equivalent of fuels produced. 2. Petitioner’s Argument Petitioner c