Section 355 of the Internal Revenue Code, which specially treats certain forms of corporate reorganization, has been the constant subject of both scholarly commentary and litigation. The experience of functioning under these spin-off provisions has resulted in clarification of the law and has also raised significant questions as to its scope. The precise limits of the section remain to some extent in a state of flux and await further exposition by the courts.
Robert A. Jacobs,
The Anatomy of a Spin-Off,
1967 Duke Law Journal
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