The transaction presumably would have qualified under section 368(a)(1) as a contractual reorganization, followed by a section 332 liquidation, but not under section 368(a)(1) as a statutory merger of consolidation.

In a B reorganization, followed by a section 332 liquidation, those cases which hold that section 203 is inapplicable to transfers in liquidation appear to permit the successor corporation to sue for refund of taxes paid by the transferor.

Berlin retired in 1973, and Frank Massi, a longtime Hearst financial officer, served as president from 1973 to 1975, carrying out a financial reorganization followed by an expansion program in the late 1970s.

In the reorganization that followed, the four Military areas created pursuant to EO No. 94, series 1947, were not altered substantially, but were nevertheless placed under the administrative and operational control of GHQ, AFP.

In the reorganization that followed the Third Congress of the LPRP in 1982, Phoumi became a member of the Inner Cabinet with overall responsibility for education, information and culture.

It followed with a reorganization of its divisions into Macy's Northeast ( former Macy's New York and Macy's New Jersey ), Macy's South / Bullock's ( Macy's Atlanta stores plus Macy's New York's operations in Texas, Florida and Louisiana ), and Macy's California, the latter including a semi-autonomous I. Magnin / Bullocks Wilshire organization.

With its reorganization, and the breath, that brought the ten main shareholders, which had a long successful experience with their business, about the alteration of the work mentality and all these followed by business plans and by clear strategy of development, " Birra Tirana " has stated its goal to become the main beer in the Albania market.

In the reorganization of the Prussian army which followed the Treaty of Tilsit, Yorck was one of the leading figures.

Nogara was a party to the negotiations on the reorganization of Italy's banks, which followed 1929 legislation bailing out the banks.

Several judicial reorganization acts followed in 1805, 1809, and 1814, though a modified form of Sargent's county court system and the considerable power held by judges continued.

On March 16, 2011 some three years after filing for bankruptcy and following a filing in a Manhattan U. S. bankruptcy court, Lehman Brothers Holdings Inc announced it would seek creditor approval of its reorganization plan by October 14 followed by a confirmation hearing to follow on November 17.

Enterprise Holdings was formed as part of a reorganization that followed Enterprise Rent-A-Car's acquisition of Vanguard Automotive Group.

A new logo, store reorganization, and a shift from stores in shopping malls to freestanding community-based stores followed.

A significant ministerial reorganization followed which resulted in the present sharing of administration and leadership among church pastors.

His death in 1923, followed by a terrible earthquake that devastated Japan in the same year, made necessary a reorganization and reconstruction of the nation's scourged economy.

Initially founded, in the reorganization of state broadcasting which followed the end of World War II, as " Paris-Inter " and charged with being French public radio's generalist ( i. e. " full-service ") service, the channel was renamed " France I " in 1958 ( even though three years later one of France's most popular radio and television listings magazines was still showing the station's programmes under the heading " Paris-Inter ", with " France I " as a subtitle ).

A reorganization of the assets of the 32nd Signal Battalion ( Corps ) to create the Brigade Headquarters and the 17th Signal Battalion followed.

In 1939 the College seemed set for a period of steady if unspectacular advance in service to the community and more immediately to the University, when the Second World War intervened and was followed by an almost complete revaluation and reorganization of University life.

At the VII meeting of the Enlarged Executive Committee of the Communist International held in Moscow between February and March of that year, Bordiga opposed “ Bolshevization ”, that is, the reorganization of the party on the basis of the factory cell that, under the pretense of increasing the workers ’ influence, had the effect of enclosing the base within the narrowness of the factory or shop, to which the person of the functionary-bureaucrat became an indispensable source of “ the line to be followed ” and the embodiment of leadership.

Until the reorganization of the provinces that followed the adoption of the 1995 constitution, this city served as the capital of the province of Gojjam.

He was appointed as chairman of the Military Affairs Committee, the primary agenda item there being the reorganization and reduction of the armed forces to put them on a peacetime footing.

In the September 1949 reorganization, military leadership was transferred to a government body, the People's Revolutionary Military Commission of the Central People's Government ( 中央人民政府人民革命军事委员会, Zhōng ​ yāng Rén ​ mín ​ zhèng ​ fǔ Rénmín Gé ​ mìng ​ jūnshì Wěi ​ yuán ​ huì ).

In a major reorganization, Headquarters Command, U. S. Air Force, was disbanded 1 July 1976, restructured under the Military Airlift Command as the 76th Airlift Division and transferred its headquarters from Bolling AFB to Andrews.

Along with the reorganization, the 1607 ATW was deactivated and the 436th Military Airlift Wing ( 436 MAW ) activated and assumed the mission at Dover.

Transferred to the retired list with the rank of admiral in October 1942, he remained on active service with the Navy Relief Society, as senior member of a " Special Joint Chiefs of Staff Committee " on the reorganization of the national defense, and as a witness before the International Military Tribunal for the Far East.

This reorganization came to an end in 1986 when the remaining four divisional headquarters were dissolved and all brigades in Northern Italy came under direct command of the Army's three Corps there, while the brigades in Central and Southern Italy came under operational control of the local administrative Military Regions.

During the interval of peace that preceded the Seven Years ' War he was engaged in carrying out an elaborate scheme for the reorganization of the Austrian army, and it was chiefly through his efforts that the Theresian Military Academy was established at Wiener-Neustadt in 1751.

In 1992, following the disestablishment of MAC as part of an Air Force-wide reorganization, the 437th Military Airlift Wing ( 437 MAW ) and 315th Military Airlift Wing ( 315 MAW ) were placed under the newly-established Air Mobility Command ( AMC ) and redesignated as the 437th Airlift Wing ( 437 AW ) and 315th Airlift Wing ( 315 AW ), respectively.

The November 1955 date was chosen as the new start date because that was when the Military Assistance Advisory Group ( MAAG ), Vietnam was separated out from MAAG, Indochina in a reorganization into the different countries that the deployments were stationed.

Priority was given to the reorganization of the National Police Force, known as " Pubblica Sicurezza " or PS, and the man entrusted to this task was a career Police officer named Arturo Bocchini.

Later on a division of the PS named " Servizio Informazioni Speciali " (" Special Informations Service ", better known as SIS ) was known to have been set up by the new Minister of Interior, the Socialist Giuseppe Romita, as a result of a new reorganization of the Police offices, with the task of taking over the management of the CPC and investigating politically motivated crimes and other felonies related to that particular time ( such as black marketeering, etc.

On 9 July 1964, the previously independent police in Paris were placed under the Sûreté Nationale, and 10 July 1966 saw the final reorganization into the National Police in its present form.

Pursuant to the Good Friday agreement of 1998, a commission chaired by former Hong Kong Governor Chris Patten had issued a plan for the reconstitution and reorganization of the Royal Ulster Constabulary into a new Police Service of Northern Ireland.

This reorganization was recommended by the McDonald Commission investigating the former security service of the Royal Canadian Mounted Police which was found to have engaged in illegal activities.

As part of the reorganization, SAC's bomber aircraft, ICBMs, strategic reconnaissance aircraft, and command post aircraft were merged with USAF fighter and other tactical aircraft assets and reassigned to the newly-established Air Combat Command ( ACC ).

The reorganization of the Portuguese Army in 2006 caused the extinction of the Airbone Troops Command.

During a 1992 reorganization, the Air Force disestablished Eglin's parent major command, Air Force Systems Command ( AFSC ) and merged its functions with the former Air Force Logistics Command ( AFLC ).

After the war, March reverted to its operational role and was assigned to the new Tactical Air Command ( TAC ) as part of the postwar reorganization of the Army Air Force.

On 1 June 1992, a major Air Force reorganization resulted in the disestablishment of the Strategic Air Command.

In a reorganization in 1964, Strategic Air Command assumed jurisdiction of the base and ADC phased down its presence to a tenant organization.

In 1961, with the formation of the Defense Intelligence Agency and reorganization within the Air Force, ATIC was reassigned to Air Force Systems Command at Andrews Air Force Base, Maryland and redesignated the Foreign Technology Division ( FTD ).

On 1 June 1992, as part of the first major reorganization since the creation of USAF, the Air Force inactivated Strategic Air Command and assigned Ellsworth's organizations ( including a renamed 28th Bomb Wing ( 28 BW )) to the newly activated Air Combat Command ( ACC ).

In conjunction with the reorganization of the Fighter Weapons School, Tactical Air Command established the USAF Tactical Fighter Weapons Center on 1 January 1966.

The result of this reorganization was Tedder's Mediterranean Air Command and its major sub-command — the Northwest African Air Forces ( NAAF ), under Lt. Gen. Carl Spaatz — was structured according to Tedder's tri-force model.

Subsequent reorganisations changed things greatly and before the final reorganization, the two Groups which made up Strike Command were:

A reorganization of the division created a new battalion, the 37th Tank Battalion, which he commanded until he was promoted to command Combat Command B of the division in March 1945.

Also, reorganization of the command structure of the U. S. Air Force saw the assignment of air defense to Tactical Air Command and later, its successor, Air Combat Command.

The USAAF Troop Carrier Command ( TCC ) was inactivated as part of this reorganization and Third Air Force was reassigned to TAC to control the troop carrier units formerly part of TCC.

Since a 2007 reorganization, its commander is a colonel who reports to the United States Army Corrections Command.

As part of the reorganization, General Headquarters Air Force is renamed Air Force Combat Command ; the new Army Air Forces organization consists of Air Force Combat Command ( its combat element ) and the United States Army Air Corps ( its logistics and training element ), ending the official use of the term " Army Air Corps ", which is continued unofficially by USAAF personnel for the rest of the war.

* March 21 – A major reorganization of the United States Army Air Forces creates the Strategic Air Command, the Air Defense Command, and the Tactical Air Command.