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What is Appleby v. Commissioner Tax Case Review about?

Theodore and Marie Appleby petitioned the Third Circuit Court of Appeals to review a decision of the Tax Court regarding whether a distribution of stock from a wholly owned subsidiary qualified as a non-taxable distribution under Section 355 of the Internal Revenue Code. The Tax Court found that the Applebys did not meet the "active business" requirement of Section 355. The Third Circuit affirmed the Tax Court

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Scribd Government Docs

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