Proliferating gains under Sec. 357(c); Letter Ruling 9032006 represents a literal reading of this section, but it is economically unsound.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on February 1, 1992. The length of the article is 3802 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Letter Ruling 9032006 revokes Letter Ruling 8730063, which was a proper solution to the problem of liability allocation under section 351 transfers as applied under section 357(c). The previous ruling allowed liabilities in transfers of property to corporations to be allocated among several different section 351 transfers. The new ruling will overstate taxable gains and property basis, and will inevitably be the focus of future litigation.

Citation Details
Title: Proliferating gains under Sec. 357(c); Letter Ruling 9032006 represents a literal reading of this section, but it is economically unsound.
Author: Dave N. Stewart
Publication:The Tax Adviser (Magazine/Journal)
Date: February 1, 1992
Publisher: American Institute of CPA's
Volume: 23 Issue: n2 Page: 86(5)

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