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Under this ruling; an acquisition of target stock followed by the target's liquidation qualified as a type C reorganization.
For example, the Tax Court recently held that the expenditures of a taxpayer who unsuccessfully attempted to develop through trial and error a new rifle bullet suited for hunting large game qualified as R&E expenditures for purposes of section 174.
Thus, the Service reasoned that the contributions qualified as prohibited sales or exchanges since they were made to satisfy funding liabilities, and that the Sec.

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