As a result, the distributions do not satisfy the QDRO exception of section 72(t)(2)(C).

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Bulas could not offer proof that the personal use of the hallway and bathroom met any exception under section 280A(c) of the Tax Code and thus, the personal use of the space trumped the business use.

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The subsidiary does not recognize gain on the distribution of any appreciated assets to the parent, which is an exception to the general rule of Section 311(b) that treats a corporate distribution of appreciated assets as a sale.

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