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Elliot Pisem and David E. Kahen, members of Roberts & Holland, write that certain liquidations, corporate formation transactions and reorganizations are ordinarily nontaxable, in the sense that neither gain nor loss is recognized by a party disposing of stock or assets in such a transaction. The IRS has recently proposed regulations that address the consequences of a transfer of assets that, after taking into account obligations assumed or taken subject to, lack net value.
April 21, 2005 at 12:00 AM
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