Kimbell-Diamond Doctrine

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Meaning of Kimbell-Diamond doctrine

The doctrine of income tax law, otherwise known as the unitary transaction rule, that where a taxpayer, who is interested primarily in obtaining a corporation’s assets, first purchases the stock of the corporation and then liquidates the corporation in order to acquire the desired assets, the separate steps taken to accomplish the primary objective are treated as a single transaction, and even though the objective is accomplished in form by a purchase of stock, the substance of the transaction is regarded as a purchase of property.

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Kimbell-Diamond doctrine in Historical Law

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