Cases: Duncan Industries, Inc. v. Commissioner, 73 T.C. 266 (1979); Affiliated Government Employees' Distributing Co. v. Commissioner, 322 F.2d 872 (9th Cir. 1963); H. B. Zachry Co. v. Commissioner, 49 T.C. 73 (1967)
Final rules 2
(a) Nonrecognition of gain or loss No gain or loss shall be recognized to a corporation on the receipt of money or other property in exchange for stock (including treasury stock) of such corporation. No gain or loss shall be recognized by a corporation with respect to any lapse or acquisition of an option, or with respect to a securities futures contract (as defined in section 1234B), to buy or sell its stock (including treasury stock).
Amended 1984, 2000
- 2000 Pub. L. 106-554 Pub. L. 106–554 inserted “, or with respect to a securities futures contract (as defined in section 1234B),” after “an option” in second sentence.
- 1984 Pub. L. 98-369 Pub. L. 98–369 inserted provision that no gain or loss shall be recognized by a corporation with respect to any lapse or acquisition of an option to buy or sell its stock (including treasury stock).
Cited by 3
(b) Basis For basis of property acquired by a corporation in certain exchanges for its stock, see section 362.