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To meet the control test under section 351, taxpayers transferring property to a corporation must in aggregate own 80 percent or more of the corporation's voting stock and 80 percent of each class of nonvoting stock after the transfer.
The group of taxpayers transferring property must in the aggregate meet the 80 percent ownership tests.
Unilateral Contract
An agreement in which only one party makes a promise to perform in exchange for an act by the other party.
Acceptance
The act of receiving or agreeing to something, such as a proposal or offer, thus constituting a contract.
Performance
The execution, accomplishment, or fulfillment of a promise, contract, or other obligation.
Revocation
The act of withdrawing, canceling, or repealing a statement, offer, or privilege, which can pertain to legal contracts, licenses, or wills.
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