Section 351 Transaction. Each party hereto acknowledges and agrees that the assignment of the Assets is intended to be treated for federal income tax purposes and relevant state and local tax purposes as an element of a tax-free transaction described in Section 351 of the Internal Revenue Code. No party hereto shall take, or cause or permit to be taken, any position that is inconsistent with such treatment in any tax return or filing or in any tax proceeding.
Appears in 4 contracts
Samples: Assignment and Assumption Agreement (Espeed Inc), Assignment and Assumption Agreement (Espeed Inc), Assignment and Assumption Agreement (Espeed Inc)