id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-370	McMahon, Jr., Martin J.; Shepard, Ira B.; Simmons, Daniel L.	Recent Developments in Federal Income Taxation: The Year 2008	2022	192	.pdf	application/pdf	86447	4081	54	The Tax Court (Judge Marvel) rejected the taxpayer’s argument and agreed with the Commissioner that the rules in §§ 302 and 304 “apply only to the shareholder who, in exchange for stock, actually receives the proceeds of a cross-chain sale. These proposed regulations deal with the net value requirement for tax-free transactions under subchapter C, and provide that exchanges under §§ 351, 332 and 368 do not qualify for tax-free treatment where there is no net value in the property transferred or received, with exceptions for E, F and some D reorganizations.	cache/ftr-370.pdf	txt/ftr-370.txt