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Also see paragraph c 5 of this section for an exception for installment obligations attributable to sales of certain property that do not generally qualify for installment method 453.Except as provided in section h 1 Cin paragraph c 4 of this section relating to certain sales of inventoryand in paragraph c 5 of this section relating to certain tax avoidance transactionsthe nature of the assets sold by, and the tax consequences to, the selling corporation do not affect whether an installment obligation is a qualifying installment obligation.The provisions of this paragraph a are illustrated by the following examples.Except as otherwise provided, assume in each example that A, an individual who is a calendar-year taxpayerowns all of the stock of T corporation.
Because P did not own the requisite 80 percent stock interest in Q, P was not a controlling corporate shareholder of Q within the meaning of section c immediately before the liquidation. Thus, in the hands of A, the C obligation is and to be a third-party note not a purchaser 's evidence of indebtedness and is treated as a payment to A in the year of distribution.
An election not to report on the installment method an liquidating obligation received in the liquidation applies to all distributions received in the liquidation.
For purposes of this section, if in the course of a liquidation a shareholder assumes secured or unsecured liabilities of the liquidating corporationor receives property from the corporation and to such liabilities including any tax liabilities incurred by the click the following article on the distributionthe amount of the liabilities is added to the shareholder's source in the stock of the liquidating corporation.
Pursuant to IRC section a , a corporation will recognize gain or loss separately on each asset that is distributed in liquidation equal to the asset's fair market value less the asset's adjusted basis.
Those temporary regulations affect corporations that distribute the stock or securities of controlled corporations and their shareholders or security holders of those distributing corporations.
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The provisions of this paragraph c 3 are illustrated by the following examples:.