purchase

(A)The term “purchase” means any acquisition of stock, but only if— (i)the basis of the stock in the hands of the purchasing corporation is not determined (I) in whole or in part by reference to the adjusted basis of such stock in the hands of the person from whom acquired, or (II) under section 1014(a) (relating to property acquired from a decedent), (ii)the stock is not acquired in an exchange to which section 351, 354, 355, or 356 applies and is not acquired in any other transaction described in regulations in which the transferor does not recognize the entire amount of the gain or loss realized on the transaction, and (iii)the stock is not acquired from a person the ownership of whose stock would, under(other than paragraph (4) thereof), be attributed to the person acquiring such stock.

Source

26 USC § 338(h)(3)(A)


Scoping language

For purposes of this section
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