Predecessor corporation. For pur- poses of section 1374(c)(1), if the basis of an asset of the S corporation is de- termined (in whole or in part) by ref- erence to the basis of the asset (or any other property) in the hands of another corporation, the other corporation is a predecessor corporation of the S cor- poration. [T.D. 8579, 59 FR 66463, Dec. 27, 1994] § 1.1374–2 Net recognized built-in gain.
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