Article Title
Realization and Recognition of Losses on Stock Surrenders: A Frolic Through Subchapter C
Document Type
Article
Abstract
A shareholder's surrender of stock to a corporation for no consideration arguably results in a realized loss to the shareholder. But should that loss be recognized? The Supreme Court's decision in Fink v. Commissioner denied loss recognition for stock surrenders resulting in only a small reduction in a shareholder's percentage ownership in a corporation. While correct in results, the analytical basis for this decision is problematic and offers a unique opportunity to examine the basic issues of loss realization and recognition within the context of subchapter C of the Internal Revenue Code.
Recommended Citation
Gwendolyn Griffith,
Realization and Recognition of Losses on Stock Surrenders: A Frolic Through Subchapter C,
17 Fla. St. U. L. Rev.
49
(1989)
.
https://ir.law.fsu.edu/lr/vol17/iss1/2