Posted: 31 Mar 2009 at 09:34 | IP Logged
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Need help with answer to these two questions
. A transferor who receives stock for both property and services cannot be included in the control group indetermining whether an exchange meets the requirements of § 351.
A person who performs services for a corporation in exchange for stock cannot be treated as a member of thetransferring group even if that person also transfers some property to the corporation.
__________________ Audit 08/17/08 R 9/18/08 80
FAR 8/28/08 R 9/23/08 62, 2/26/09-92
BEC- Retake 02-25 BEC Rec'd 3/19/ 86
REG/ 11/23/2009 75
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