Fair Market Value of Appreciated Property Distribution to Shareholders Determined Based on Form of Distribution Out of Corporation, Not on Form Received by Shareholders: Pope & Talbot, Inc. v. Commissioner
In Pope & Talbot, Inc, v. Commissioner, the Ninth Circuit held that the corporate taxpayer's gain on the distribution of appreciated property to a newly formed limited partnership, which then distributed limited partnership interests pro rata to the corporation's shareholders, was determined by reference to the value of the appreciated property...
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