I am looking for a copy of a Technical Memorandum from the IRS in 1956
that accompanied Treasury Decision 6210. It is cited in GCM 34794"
"The Technical Memorandum accompanying T.D. 6210 under which Regs.
1.1036-1(a) was adopted stated that that provision was "inserted merely
to indicate that section 1036 applies without regard to the voting
rights of the stock involved in the exchange. "
I haven't had any luck in finding it in any of our print (CB, CCH, etc.)
or electronic (Lexis, Westlaw, RIA Checkpoint) resources. Does anyone
have a copy of the Memorandum that you could fax or e-mail to me, or any
suggestions about where else to look? Thank you!
Emily Riegle
Porter, Wright, Morris & Arthur
Columbus, OH 43215
Voice: 614-227-2090
Fax: 614-227-2100
**********Notice from Porter Wright Morris & Arthur LLP**********
This message may be protected by the attorney-client privilege. If you believe that it has been sent to you in error, do not read, print or forward it. Please reply to the sender that you have received the message in error. Then delete it. Thank you.
To comply with certain U.S. Treasury regulations, we inform you that any federal tax advice contained in this message, including attachments, is not a covered opinion as described in Treasury Department Circular 230 and therefore cannot be relied upon to avoid any tax penalties or to support the promotion or marketing of any federal tax transaction.
********************End of Notice********************
This archive was generated by hypermail 2b29 : Wed Nov 14 2007 - 20:46:37 PST