PRACTISING LAW INSTITUTE - Steptoe

However, the mergers may not qualify as tax-free since historic shareholder continuity is lacking. See Yoc Heating Corp. v. Comm’r, 61 T.C. 168 (1973). But see Treas. Reg. § 1.368-1(e). If the mergers are not tax-free, each merger should be treated as a taxable sale of assets followed by a deemed liquidation. ................
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