C.F.R. » Title 26 » CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY › SUBCHAPTER A—INCOME TAX › PART 1—INCOME TAXES

26 C.F.R. § 1.317-1

Property defined

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The term property, for purposes of part 1, subchapter C, chapter 1 of the Code, means any property (including money, securities, and indebtedness to the corporation) other than stock, or rights to acquire stock, in the corporation making the distribution.

Notes of Decisions
Cited in 6 cases, 1963–1998 · leading case: CTM Constr., Inc. v. Comm'r, 56 T.C.M. 971 (T.C. 1988).
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CTM Constr., Inc. v. Comm'r, 56 T.C.M. 971 (T.C. 1988). · cites it 2× “, provides that "the term 'property' * * * means any property (including money, securities, and indebtedness to the corporation) other than stock or rights to acquire stock, in the corporation making the distribution.”
Shephard v. Comm'r, 22 T.C.M. 1502 (T.C. 1963). · cites it 4× “301-1(m) of the Regulations provides that the cancellation of indebtedness of a shareholder by a corporation shall be treated as a distribution of property and section 317 of the Code and section 1.”
Spera v. Comm'r, 75 T.C.M. 2540 (T.C. 1998). · cites it 2× “Section 316(a) defines dividends as any distribution of property made by a corporation to its shareholders out of its earnings and profits. Section 1.317-1, Income Tax Regs.”
Tabery v. Comm'r, 23 T.C.M. 1108 (T.C. 1964). · cites it 2× “The term "property" includes an indebtedness owed to the corporation.”
Winnek v. Comm'r, 24 T.C.M. 1400 (T.C. 1965). · cites it 2× “See Income Tax Regs., sec. 1.317-1 ; Bradbury v. Commissioner, (C.”
Graham v. Comm'r, 35 T.C.M. 1315 (T.C. 1976). · cites it 2× “--For purposes of this subtitle, the term "dividend" means any distribution of property made by a corporation to its shareholders-- (1) out of its earnings and profits accumulated after February 28, 1913, or (2) out of its earnings and profits of the taxable year (computed as of…”
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