All Theses, Dissertations, and Capstone Projects

Year of Award



Master of Science in Taxation (MST)


College of Business & Professional Studies

Degree Program



Business Administration


shareholder, capital, interest, dividend, profits


Section 304 of the Internal Revenue Code1 was originally enacted as an anti-tax-avoidance provision to protect the integrity of the redemption provisions of the Code in situations where the stock of one corporation was sold to a related corporation.2 The original concern of this section was the conversion of ordinary income to capital gain income. While this concern has been somewhat alleviated with the elimination of the capital gain tax rate advantage, there remains a valid concern in regards to the classification of income for the purpose of deducting capital losses for corporations. Section 304 seeks to recast a reported simple sale of stock into a stock redemption transaction that often results in dividend treatment to the seller.

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