(C) Gain. The special gain limitation rules in paragraph (e)(2) or (3) of this section do not apply because there is not an acquisition of stock of D or a Predecessor of D. Therefore, because there is a Planned 50-percent Acquisition of R (Successor of D), D is required to recognize $20x of gain ($30x fair market value minus $10x basis of the C stock held by D), the Statutory Recognition Amount described in section 355(c)(2).


26 CFR § 1.355-8T

Scoping language

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