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Tax Lawyer, Vol. 62, No. 2 PROHIBITION ON THE TAXABLE ASSET SALE 357357Regarding the Advisability of a Prohibition on the Taxable Asset Sale to Creditors in BankruptcyCarlARL N. PicICkerillERILL*I. IntroductionJust over five years ago, the Service issued a Chief Counsel Advisory memo—CCA 2003-50-016 (CCA)—approving a reorganization transaction between a debtor corporation (Debtor) in Chapter 11 and its creditors.1 The parties structured the transaction as a taxable sale of the Debtor’s assets to...