...Claire Y. Nash ABSTRACT Under Section 302(b)(3), a taxpayer who redeems all of the stock he owns in an S corporation is treated as having surrendered his stock in a fully taxable exchange. The taxpayer generally recognizes the gain, or loss, realized on the exchange. Moreover, if the interest he...

.... Section 469(g) Section 1411 aggregate theory entity theory S corporations partnerships passthrough entities net investment income tax When the sale or exchange of the taxpayer's entire interest in a passive activity is to a related party, however, Congress felt that the economic losses...