basis in [C]'s stock is an allocable part of [D]'s basis in S's
pacemaker as a knowledgeable patient advocate, but not personally to order the discontinuation.
The deferred gain from the prior stock sale ($190) is thus duplicated when the P group elects the deemed asset sale treatment (the $390 total gain on the asset sale to X includes $200 of appreciation attributable to B's holding period for T plus the $190 attributable to S's
holding period for T).
relatives need timely warning of their possible genetic risk, and counselling regarding the disease, with discussion of their reproductive options as required.
E proffered five discrete nontax rationales for S's
transfer of assets to SFLP:
For example, if S sells the stock of another member to B, S's
gain or loss on a separate entity basis is determined with the application of Treas.
The ruling held that S's
distribution of the P debt was a distribution under Sec.
1502-32(b)(3)(iv), P's basis in S's
stock would be reduced by any distributions from any source of S's
In year 1, the average balance of S's
exempt obligations is $500 and the average balance of S's
total assets is $1,000; P's interest expense on the loan from X is $2.
The proposed negative adjustments to account for S's
If a holding company were used, stock losses based on S's
loss might be multiplied by more than two taxpayers, if the stocks of the holding company and of S were sold from the "top down" before S sold its assets.
The sale of the CS2 does not result in S's