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INCOME TAX PROJECT 1 (NON-RECOGNITION OF GAIN OR LOSS LUNCHEON MEETING, November 30, 1948)

handle is hein.ali/aliftp0436 and id is 1 raw text is: Luncheon Meeting Room B, Downtown Association, 60 Pine Street, N. Y. C. 11:30 p.m., November 30, 1948 Subject,: Non-Recognition of Gain or Loss AGENDA I. Proposed organization. A. Voluntary transactions. 1. Combination into larger units, and acquisitions. 2. Division into smaller units, and dispositions. B. Involuntary transactions. 1. Involuntary conversions. 2. Transactions in a receivership, or a bankruptcy or reorganization proceeding under the National Bankruptcy Act. 3. Creditor arrangements not under the National Bankruptcy Act nor a receivership proceeding. 4. Transactions pursuant to court decrees or administrative deter- minations, involving the application of Federal and state laws. II. Examination of Section 112 to determine to what extent its present provi- sions should be retained. A. Section 1l2(b)(1): (1) Property Held for Productive Use or Investment. -- No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment. 1. Should this section continue to apply to investment property? 2. Should we try to define trade or business as used herein in light of cases, such as Leland Hazard, 7 T.C. 372 (1946) a. 1946-2 C.B. 3, and N, Stuart Campbell, 5 T.C. 272 (1945).