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reorganization periodi recall that there is a 2 year 'safe harbor' for a corporate taxpayer that has engaged in a tax free (really tax deferred) reorganization transaction during which 2 year period the tax free status of the reorganization is at risk if the corporation engages in certain other transactions. my question is where in regulations, if at all, is the authority for this 2 year safe harbor? maybe it's not in regulations but some other authority? thanks. |
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