Louisiana law, there was a "C" reorganization. The old corporation transferred substantially all its assets. W.H. George, 26 TC 396, Dec. 21,762 (Acq.). c. 1939 Code Sec. 112(g)(1)(C)—similar to 1954 Code Sec. 368(a)(1)(C)] d. Rev. Rul. 78-47, 1978-1 CB 113,Rev. Rul. REVRUL78-47,Internal Revenue Service,(Jan. 1, 1978) The question in the instant case is whether Y transferred “substantially all” of its assets to X as required by section 368(a)(1)(C) of the Code, since Y's…
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