CH. 1—NORMAL TAXES AND SURTAXES (4)
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C O N S T R U C T IV E O W N E R S H I P AS ACT U A L O W N E R S H I P. —
(A) IN GENERAL.—Except as provided in subparagraph (B),
stock constructively owned by a person by reason of the appHcation of paragraph (1), (2), or (3) shall, for purposes of applying paragraph (1), (2), or (3), be treated as actually owned by such person. (B) M E M B E R S OF FAMILY.—Stock constructively owned by an individual by reason of the application of paragraph (1) shall not be treated as owned by him for purposes of again applying paragraph (1) in order to make another the constructive owner of such stock, (C) OPTION RULE IN LIEU OF FAMILY RULE.—For purposes of
this paragraph, if stock may be considered as owned by an individual under paragraph (1) or (3), it shall be considered as owned by him under paragraph (3).
- (b) CROSS R E F E R E N C E S. —
For provisions to which the rules contained in subsection (a) apply, see— ]; (1) section 302 (relating to redemption of stock); (2) section 304 (relating to redemption by related corporations); J (3) section 306(b)(1)(A) (relating to disposition of section 306 ' stock); (4) section 334(b)(3)(C) (relating to basis of property received in certain liquidations of subsidiaries); and (5) section 382(a)(3) (relating to special limitations on net operating loss carryovers).
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PART II—CORPORATE LIQUIDATIONS Subpart A. Effects on recipients. Subpart B. Effects on corporation. Subpart C. Collapsible corporations; companies. Subpart D. Definition.
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Subpart A—Effects on Recipients Sec. Sec. Sec. Sec.
331. 332. 333. 334.
Gain or loss to shareholder in corporate liquidations. Complete liquidations of subsidiaries. Election as to recognition of gain in certain liquidations. Basis of property received in liquidations.
SEC. 331. GAIN OR LOSS TO SHAREHOLDERS IN CORPORATE LIQUIDATIONS.
(a) GENERAL RULE. — (1) COMPLETE LIQUIDATIONS.—Amounts distributed in complete
liquidation of a corporation shall be treated as in full payment in exchange for the stock. (2) PARTIAL LIQUIDATIONS.^—Amounts distributed in partial liquidation of a corporation (as defined in section 346) shall be treated as in part or full payment in exchange for the stock. (b) NONAPPLICATION OF SECTION 301.—Section 301 (relating to effects on shareholder of distributions of property) shall not apply to any distribution of property in partial or complete liquidation.
331(b)
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