Tsn liquidating corp v us

We recommend downloading the following to your Windows desktop, or to your downloads folder.We are constantly working to improve our drivers and software.The company was “administratively dissolved” some time after, for example, effective January 25, 2008, due to its failure to timely pay state franchise taxes.Company management, however, was blissfully unaware of this development and continued to file the business’s federal corporate income tax return and pay all federal income taxes.martin-marietta-corporation-a-corporation-of-the-state-of-maryland-v-new , 653 F.2d 779 ( 1981 ) stones-pharmacy-inc-v-pharmacy-accounting-management-inc-dba-pam , 812 F.2d 1063 ( 1987 ) Bergen, Johnson and Olson v. Sterling Corporation , 393 F.3d 276 ( 2005 ) Polaroid Corp. This requirement has its origins in cases datingback to The Internal Revenue Service ("Service" or "IRS")considers the continuity of interest requirement as satisfiedif, following the transaction, historic shareholders of thetarget corporation hold stock of the acquiring corporation (as aresult of prior ownership of target stock) representing at least50% of the value of the stock of the target corporation. 19 Note that the new COI regulations do not apply to section 368(a)(1)(D) reorganizations or section 355 transactions. Under the law prior to the issuance of the final COIregulations in January 1998, the Service, and to a lesser extentthe courts, applied the step-transaction doctrine to determineif the COI requirement was satisfied.

Witness the situation described in recent letter from the Internal Revenue Service (LTR 200806006, November 7, 2007), which addresses a seeming anomaly related to the tax code.

The last substantial distribution can be used only if, at that time, the amount of the final distribution is both de minimis and determinable with “reasonable certainty.” (See in this regard Rev. Footnotes *Except in instances where the liquidation is governed by Section 332(a), and Section 337(a).

In that case, the distributee shareholder is another corporation which owns at least 80 percent of the voting power and value of the liquidating entity’s stock on the date of the planned complete liquidation is adopted and all times thereafter until the receipt of the property.) **When a complete liquidation is followed by a pre-arranged transfer of all or part of its essential operating assets to a second (almost always newly-created) controlled corporation, the steps may be “collapsed” and treated as a single, unitary transaction which bears an unmistakable resemblance to a reorganization. 1.331-1(c) “…a liquidation which is followed by a transfer to another corporation of all or part of the assets of the liquidating corporation…may have the effect of…a transaction in which no loss is recognized and gain is recognized only to the extent of other property…”) In LTR 200806006, however, it is highly unlikely that, if the dissolution had caused a liquidation, such liquidation would have been “stepped together” with the reincorporation (to find a reorganization).

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