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Tax Section 311 Taxability of a Corporation on Dividends

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Issue:

Business

 

Written by:

Joseph M

 

Date added:

November 10, 2012

 

Level:

University

 

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No of pages / words:

4 / 862

 

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5324 times

 

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Essay content:

311(d) as if it had instead sold the entire interest to a single purchaser. The taxpayer had argued that the fair market value of the distributed property for purposes of determining Internal Revenue Code Sec. 311 gain must be equal to the sum of the distributed partnership interests, which were publicly traded on the date of distribution...
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The commissioner proposed an $18.7 million deficiency determination against Pope & Talbot for the 1985 and 1986 taxable years, alleging that Pope &Talbot had incorrectly calculated the corporation's gain under IRC Sec.31(d). [IRC Sec. 311(d) was amended in 1986 and is now IRC Sec. 311(b).] Pope & Talbot had, in 1985, contributed its timber, land development, and resort business to a newly formed Delaware limited partnership...
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