26 C.F.R. § 1.312-5
Special rule for partial liquidations and certain redemptions
The part of the distribution properly chargeable to capital account within the provisions of section 312(e) shall not be considered a distribution of earnings and profits within the meaning of section 301 for the purpose of determining taxability of subsequent distributions by the corporation.
Notes of Decisions
Cited in 2
cases, 1985–1985 · leading case: Woods Inv. Co. v. Comm'r, 85 T.C. 274 (Tax Ct. 1985).
Woods Inv. Co. v. Comm'r, 85 T.C. 274 (Tax Ct. 1985). “172 net operating loss deduction (see sec. 1.312-5(d), Income Tax Regs.”
Est. of De Niro v. Comm'r, 49 T.C.M. 1004 (Tax Ct. 1985). “]; and (3) certain items that cannot be deducted in computing taxable income which may be deducted in computing the earnings and profits such as Federal income taxes, excess charitable contributions, and nondeductible losses [see section 1.”
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