<b><i>Part Two of a Two-Part Article</i></b>. Even the IRS appears to have some reservations about its position, particularly as such position is applied to the corporate transferee collecting payments on a shareholder note received as a capital contribution in a Section 351 transaction (or otherwise).
Elias M. ZuckermanPart Two of a Two-Part Article
Even the IRS appears to have some reservations about its position, particularly as such position is applied to the corporate transferee collecting payments on a shareholder note received as a capital contribution in a Section 351 transaction (or otherwise).
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