Open transaction doctrine does not apply where stock basis can be reasonably allocated

Insurance Tax Bulletin

The US District Court for the District of Arizona recently held that the basis of shares received in a demutualization transaction could be reasonably determined, that the open transaction doctrine did not apply, and that the basis of the shares should be apportioned according to Treas. Reg. Section 1.61-6(a).



Return to Tax research and insights
Insurance Tax Bulletin newsletter archive