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Re: None

Wednesday, 12/13/2023 6:30:29 PM

Wednesday, December 13, 2023 6:30:29 PM

Post# of 13962
I think D is where we’re at thanks to the reorganization plan. I also like this. So. Good

(B) Stock acquired in taxable transactions within 5 years treated as boot.
For purposes of this section (other than paragraph (1)(D) of this subsection) and so much of section 356 as relates to this section, stock of a controlled corporation acquired by the distributing corporation by reason of any transaction—
(i) which occurs within 5 years of the distribution of such stock, and
(ii) in which gain or loss was recognized in whole or in part,
shall not be treated as stock of such controlled corporation, but as other property.
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