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IRS Private Letter Ruling Makes It Easier to Qualify for Deferral of Taxes in Connection with Sale of Stock to Employee Stock Ownership Plan (PDF)
Morgan Lewis 
[Guidance Overview] Nov. 10, 2008
2 pages. Excerpt: In Private Letter Ruling 200827018, the IRS ruled that for purposes of deferring tax under Section 1042 of the Internal Revenue Code (the Code), a shareholder's holding period in the company's stock includes the period during which the shareholder held membership interests in a limited liability company that was the company's predecessor.
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