 ... has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings...  Reports of the U.S. Board of Tax Appeals - Page 578by United States. Board of Tax Appeals - 1934Full view - About this book
 | Administrative law - 1968 - 260 pages
...has the effect of the distribution of a dividend, then there shall be treated as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as Is not in excess oí his ratable share of the undistributed earnings and profits of the corporation accumulated after... | |
 | United States. Tax Court - Taxation - 1945 - 1518 pages
...the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized...be taxed as a gain from the exchange of property." As we have already pointed out the reorganization Involved the receipt by the stockholders of the Old... | |
 | United States. Tax Court - Taxation - 1947 - 1314 pages
...of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of gain recognized under paragraph (1) as Is not in excess...be taxed as a gain from the exchange of property. •Report of Ways and Means Committee (68th Cong., 1st Bess., H. Kept. 179, pp. 14-16) : "(2) There... | |
 | United States. Tax Court - Law reports, digests, etc - 1959 - 1456 pages
...the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized...1913. The remainder, If any, of the gain recognized nnder paragraph (1) sbaU be taxed as a gain from the exchange of property. •SEC. 101. EXEMPTIONS... | |
 | United States. Tax Court - Law reports, digests, etc - 1947 - 1354 pages
...the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized...earnings and profits of the corporation accumulated after Febraary 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be taxed... | |
 | United States. Tax Court - Taxation - 1970 - 1856 pages
...tzeh distributee such an amount of the gain recognized under paragraph (1) as Is not la excess of bis ratable share of the undistributed earnings and profits...of the gain recognized under paragraph (1) shall be treated as gain from the exchange of property. 'JSEC. 331. GAIN OR LOSS TO SHAREHOLDERS IN CORPORATE... | |
 | United States. Internal Revenue Service - Internal revenue - 1974 - 624 pages
...treated as a dividend to each distributee such an amount of the gain recognized under section 356 (a) ( 1 ) as is not in excess of his ratable share of the...the corporation accumulated after February 28, 1913, and the remainder, if any, of the recognized gain will be treated as gain from the exchange of property.... | |
 | United States. Internal Revenue Service - Internal revenue - 1975 - 804 pages
...treated as a dividend to each distributee such an amount of the gain recognized under section 356 (a)(l) as is not in excess of his ratable share of the undistributed...the corporation accumulated after February 28, 1913, and the remainder, if any, of the recognized gain will be treated as gain from the exchange of property.... | |
 | United States. Congress. House. Committee on Ways and Means - Income tax - 1969 - 1728 pages
...then there shall be treated as a dividend to each distributee such amount of the gain recognized * * * as is not in excess of his ratable share of the undistributed earnings and profits of the corporation * * *." This is construed by the Internal Revenue Service as making boot constituting gain automatically... | |
 | United States. Internal Revenue Service - Internal revenue - 1978 - 630 pages
...amount of the gain recognized under section 356 ( a) (1) as is not in excess of each distributee's ratable share of the undistributed earnings and profits...corporation accumulated after February 28, 1913. The reminder, if any, of the recognized gain will be treated as gain from the exchange of property. Section... | |
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