Sec. 1.346-3 Effect of certain sales.
The determination of whether assets sold in connection with a partial liquidation are sold by the distributing corporation or by the shareholder is a question of fact to be determined under the facts and circumstances of each case.
[Adopted by T.D. 6152, 20 FR 8875, Dec. 3, 1955; republished by T.D. 6500, 25 FR 11607, Nov. 26, 1960.]