This Note demonstrates that by applying the meaning of "complete liquidation" developed in several liquidation-reincorporation cases to the obviously distinguishable facts of FEC, the Court of Claims has adopted an unnecessarily restrictive view of section 337's "complete liquidation" requirement...
This Note has demonstrated that although the liquidation-reincorporation cases appear to support the traditional view that a "complete liquidation" cannot occur during a reorganization, when taken in context they are weak authority for the holding in FEC.
James H. Lokey, Jr.,
Section 337 Sales as Part of Reorganizations,
31 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol31/iss3/3