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from Brown Corpus
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Other sections of the 1954 Internal Revenue Code provide for survival of certain of a transferor's tax attributes following a tax-free reorganization.
Section 362 requires carryover of the transferor corporation's basis for property transferred, and section 1223 provides for tacking on the transferor's holding period for such property to that of the transferee.
Section 169 permits a person acquiring grain-storage facilities to elect to continue amortization over a 60-month period.
However, a similar privilege was not specifically provided in section 168 for a person acquiring emergency facilities.
Attributes similar to a loss carryover.

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