02-13-1984 Industrial Development Corporation Board of Directors Meeting (2)

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• '` • ~- _...! year period preceding the date of exchange. Treas. Reg. §1.103-10(b)(2)(v)(a), (b); Treas. Reg. §1.103-103- 10(f) Example 17 ("A" reorganization with boot). 11. Exchange of stock in a tax-free "3" reorganization; but the parent and subsidiary are treated as related through- out the six-year period. Rev. Rul. 75-~11, 1975-2 C.E. al, 12. A corporation's cash purchase of 100 percent o= the stock of another corporation (which later finances a facility with tax-exempt bonds) which will not be liqui- '' dated within two years, but which will be operated as an autonomous subsidiary of the acrn:iring corporation. The corporations will, however, be. treated as related parties throughout the-six-year period at least if they are related on the date of the issue. LTR 8008136. 13. Issuance of a partnership interest_in tax-free exchange under Section 721 of the Code for property, at least where •the partner purchased the: property more than 3 years before the- issuance of the bonds. Rev. Rul. 4 • 77-146, 1977-1 C.B. 2~. ~- 14. If the present owner purchased the facility within the six-year period; the purchase price is a capital ex- pendi tune, but the prior owner'-s~ capital expenditures • with respec~: to the facility may be disregarded to t_he ,~ extent they are reflected in the purchase price. Rev. Rul: 76-427, 1976-2: C.B. 28. See LTR 8011062. 15. Ccst to replace property damaged or cestroyed by fire, sto ^t, or other casualty to the extent not in excess of the fair market value (determined i~-znediately before the casualty) of the property replaced. Treas. Reg. §1.103-10(b)(2)(iv)(c). 16. Exnenditu=es b_v a Section 501(c)(3) charitable organiza- tior. for cha_ita:o le activities are not Section 103(b) (b)(D) capital expenditures for purposes of a related person's small issue financing of an unrelated facility. Rev. Rul. 74-289, 1974-1 C.B. 32. See LTR 8011062. 17. Expenditures by ~ political subdivision paid or incurred in carrying cut its statutory purposes are not Section 103(b)(6)(D) capital expenditures fcr purposes of a ~ srr.all issue financing of an unrelated facility. LTR •- 8012090.