irs revenue ruling 99 6 situation 1

Situation 1 of Rev. Certain of these members realized gains under section b the "Prior Intercompany Gains" as a result of the Prior Intercompany Distributions. Assume that the market interest rate was 10 percent on the date Adrett was formed. Property mixing bowl. If a member were to sell only the preferred stock portion of its interest, the cost of that interest would take into account the amount of capital the member is selling, the preferred return rate, and the market interest rate.

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