Sales Having a Tax-Avoidance Purpose - Loss Recognition Is Restricted

question 21

Short Answer

Sales having a tax-avoidance purpose - Loss recognition is restricted where property is transferred to the corporation in a Sec.351 transaction or capital contribution after a date two years before the date that the corporation adopts a plan of complete liquidation.Tax avoidance is inferred in these situations unless the corporation uses the property in its trade or business.
A less-often encountered situation involves distributions or sales of a subsidiary corporation's stock.A corporation can elect under Sec.336(e)to treat the sale,exchange,or distribution of a subsidiary's stock as a disposition of all the subsidiary's assets,resulting in no gain or loss being recognized on the sale,exchange,or distribution of the stock.

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Definitions:

Orbital Frontal Cortex

A region of the prefrontal cortex located just above the eyes that is involved in decision-making, impulse control, and responding to rewards.

Social Context

is the immediate physical and social setting in which people live or in which something happens or develops. It includes the culture that the individual is educated or lives in, and the people and institutions with whom they interact.

Amygdala

A part of the brain involved in emotion regulation, emotional learning, and forming memories associated with emotional events.

Nucleus Accumbens

A region in the brain's forebrain that plays a central role in the reward circuit, associated with pleasure, reinforcement learning, and addiction.