Irc 267 does not apply to a distribution of loss propert y in a complete corporate liquidation. The amendment made by this section amending this section shall apply to sales and other dispositions of property acquired after december 31 2015 by the taxpayer in a sale or exchange to which section 267 a 1 of the internal revenue code of 1986. Postf 105947 12 9 section 267 c provides in part rules for attributing a beneficiary s proportionate ownership interest in stock owned by or for a trust to such beneficiary and to others e g family members.
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