First Page
196
Abstract
Mr. Ellis examines the tax consequences arising when a taxpayer sells appreciated property to a controlled corporation in order to realize a capital gain for himself as well as to increase the basis of the property. He points out the dangers inherent in such a transaction and suggests precautions which should be taken to obtain favorable tax treatment. The author concludes that a taxpayer transferring appreciated property to a controlled corporation may achieve substantial tax benefits because of the relative ineffectiveness of sections 351 and 1239; however, it will be almost impossible for a taxpayer to recognize a loss on the transfer of depreciated property because of section 267.
Recommended Citation
Brian C. Ellis,
Tax Problems in Sales to Controlled Corporations,
21 Vanderbilt Law Review
196
(1968)
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol21/iss2/2