§997 — Special subchapter C rules

2 cases·2 cited

For purposes of applying the provisions of subchapter C of chapter 1, any distribution in property to a corporation by a DISC or former DISC which is made out of previously taxed income or accumulated DISC income shall—

(1)

be treated as a distribution in the same amount as if such distribution of property were made to an individual, and

(2)

have a basis, in the hands of the recipient corporation, equal to the amount determined under paragraph (1).

  • Treas. Reg. §Treas. Reg. §1.997-1 Special rules for subchapter C of the Code
  • Treas. Reg. §Treas. Reg. §1.997-1(a) For purposes of applying the provisions of sections 301 through 395 of the Code, any distribution in property to a corporation by a DISC, or former DISC, which is made out of previously taxed income or accumulated DISC income shall be treated as a distribution in the same amount as if such distribution of property were made to an individual, and have a basis, in the hands of the recipient corporation, equal to such amount treated as having been distributed.
  • Treas. Reg. §Treas. Reg. §1.997-1(b) §1.997-1(b)

2 Citing Cases

- 10 - October 3, 2003.5 The executors also elected under New York Tax Law section 997 (McKinney 1999) to pay New York estate tax in 10 annual installments.

Ewald v. Commissioner 2 T.C. 384 · 1943

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