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Archive for the ‘Stock Sales’ Category

Stock Surrender and Repurchase Lacks Economic Substance

Published: September 27th, 2017

By: Stephen R. Looney

It has long been a basic tenet of federal tax law that, in order to be respected for tax purposes, a transaction must have economic substance.  In a recent decision, the Tax Court once again held that a purported sale or exchange lacking in economic substance will not be respected.  The case also demonstrates that […]

Steve Looney Publishes Article in the Journal of Passthrough Entities

Published: January 29th, 2014

By: Stephen R. Looney

Dean Mead attorney Stephen Looney authored a “Tax Tip” article in the January-February 2014 Edition of the Journal of Passthrough Entities,  entitled “The Case of the Disappearing Basis: Stock Acquisitions by S Corporations Followed by QSub Election.”  The article highlights how purchase price basis disappears when an S corporation acquires the stock of a target corporation and then […]