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Conflicting Definitions of "Liabilities" Threatens Some Tax-free Reorganizations

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Title: Conflicting Definitions of "Liabilities" Threatens Some Tax-free Reorganizations
Author: Phelan, Marilyn E.
Abstract: The assumption of "liabilities" in reorganizations and Section 351 transfers can constitute boot and create taxable gain in an otherwise tax-free transaction. But what are "liabilities" for this purpose? Recent cases have raised conflicting theories about their nature (particularly for cash basis taxpayers), which can adversely affect a wide range of corporate transfers. Professor Phelan analyzes the impact of these late developments in the reorganization area.
URI: http://hdl.handle.net/10601/1624
Date: 1974

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