Subchapter C earnings and profits. IPT does not have any earnings and profits in excess of $1 million accumulated in any non-REIT year within the meaning of Section 857 of the Code, including as a result of the AMIT Merger.
Appears in 7 contracts
Samples: Agreement and Plan of Merger (Farkas Andrew L), Agreement and Plan of Merger (Farkas Andrew L), Agreement and Plan of Merger (Farkas Andrew L)
Subchapter C earnings and profits. As of October 1, 1998, IPT does did not have any earnings and profits in excess of $1 million accumulated in any non-REIT year within the meaning of Section 857 of the Code, including as a result of the AMIT Merger.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Insignia Properties Trust /)
