Duquesne Law Review


The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether section 351 or section 304 of the Internal Revenue Code of 1954 governs a transfer of the stock of a brother corporation to a sister corporation by the common controlling shareholder in return for stock of the sister corporation and cash.

Coates Trust v. Commissioner of Internal Revenue, 480 F.2d 468 (9th Cir.), cert. denied, 94 S. Ct. 551 (1973).

Commissioner of Internal Revenue v. Stickney, 399 F.2d 838 (6th Cir. 1968).

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