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" Options created pursuant to a title 11 or similar case. Options created by the solicitation or receipt of acceptances to a plan of reorganization in a title 11 or similar case... "
Staff Recommendations to Revise Subchapter C: Hearing Before the ... - Page 376
by United States. Congress. Senate. Committee on Finance. Subcommittee on Taxation and Debt Management - 1986 - 535 pages
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Code of Federal Regulations: Containing a Codification of Documents of ...

1993 - 956 pages
...similar case. Options created by the solicitation or receipt of acceptances to a plan of reorganize tion in a title 11 or similar case (within the meaning of section 368(aX3XA)). the option created by the confirmation of the plan, and any option created under the plan prior to...
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The Code of Federal Regulations of the United States of America

1997 - 948 pages
...similar case. Options created by the solicitation or receipt of acceptances to a plan of reorganization in a title 11 or similar case (within the meaning of section 368(a)(3)(A)), the option created by the confirmation of the 26 CFR Ch. I (4-1-97 EdHton) plan, and...
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The Bankruptcy Tax Act and Minor Tax Bills: Hearing Before the Subcommittee ...

United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures - 1979 - 264 pages
...CERTAIN STOCK RECEIVED FOR INDEBTEDNESS. — "(1) SUBSECTION (a). — For purposes of subsection (a), stock in the corporation which is acquired by a security...11 or similar case (within the meaning of section 368(a) (3) (A) ) shall be treated as not acquired by purchase, unless the claim was acquired for the...
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The Bankruptcy Tax Act and Minor Tax Bills: Hearing Before the Subcommittee ...

United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures - 1979 - 268 pages
...CERTAIN STOCK RECEIVED FOR INDEBTEDNESS. — "(1) SUBSECTION (a). — For purposes of subsection (a), stock in the corporation which is acquired by a security...extinguishment or relinquishment (in whole or in part) of n claim against the corporation in a title 11 or similar case (within the meaning of section 368(a)...
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The Code of Federal Regulations of the United States of America

1998 - 1146 pages
...similar case. Options created by the solicitation or receipt of acceptances to a plan of reorganization in a title 11 or similar case (within the meaning of section 368(a)(3)(A)), the option created by the confirmation of the plan, and any option created under the...
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Legal Opinion Letters: A Comprehensive Guide to Opinion Letter Practice

M. John Sterba - 2002 - 1903 pages
...368(a)(2)(F)(iii) and (iv) OF THE INTERNAL REVENUE CODE. 13. TARGET IS NOT UNDER THE JURISDICTION OF A COURT IN A TITLE 11 OR SIMILAR CASE WITHIN THE MEANING OF SECTION 368(a)(3)(A) OF THE INTERNAL REVENUE CODE. 14. THE FAIR MARKET VALUE OF THE ASSETS OF TARGET TRANSFERRED...
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Bankruptcy and Insolvency Taxation

Grant W. Newton, Robert Liquerman - 2005 - 768 pages
...CASES. — If a corporation completely liquidates pursuant to a plan of complete liquidation adopted in a title 11 or similar case (within the meaning of section 368(a)(3)(A)): (1) for purposes of subsection (a), the term 'property' shall not include any item acquired...
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Tax Haven Abuses: The Enablers, the Tools and Secrecy : Hearing ..., Part 2

United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations - 2006 - 1648 pages
...investment trust, as defined in the Code. 17. Kid Atlantic is not under the jurisdiction of a court in a Title 11 or similar case within the meaning of Section 368 (a) (3) (A) of the Code. 18. On December 2, 1991, as amended December 22, 1991, Anderson entered...
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Income Tax Regulations, As of January 2008

CCH Tax Law Editors - 2008 - 1872 pages
...proceedings. — If a change in a term of a debt instrument occurs pursuant to a plan of reorganization in a title 11 or similar case (within the meaning of section 368(a)(3)(A)), a modification occurs upon the effective date of the plan. Thus, unless the plan becomes...
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