Beauty and health products; bedding; clothing and accessories; electronics; food; furniture; housewares; jewelry; gardening supplies; pet supplies; shoes; sporting goods; toys/games; small appliances; Office Supplies; Books Target Corporation is the second-largest discount store retailer in the United States, behind Walmart, and a component of the S&P 500 Index.
Founded by George Dayton and headquartered in Minneapolis, Minnesota, the company was originally named Goodfellow Dry Goods in June 1902 before being renamed the Dayton's Dry Goods Company in 1903 and later the Dayton Company in 1910.
The Secretary may prescribe regulations under which, in lieu of disallowing a loss under subparagraph (A) for a prior taxable year, the gross income of the liquidating corporation for the taxable year in which the plan of complete liquidation is adopted shall be increased by the amount of the disallowed loss. 100–647, § 1006(e)(21)(A), substituted “liabilities” for “liabilities in excess of basis” in heading. For purposes of section 56 of the Internal Revenue Code of 1986 (as amended by this Act), any gain or loss not recognized by reason of this paragraph shall not be taken into account in determining the adjusted net book income of the corporation.
In the case of any liquidation to which section 332 applies, no loss shall be recognized to the liquidating corporation on any distribution in such liquidation. in the case of stock or voting trust certificates acquired from an employee or retiree of such corporation, the spouse, child, or estate of such employee or retiree or a trust created by such employee or retiree which is described in section 1361(c)(2) of the Internal Revenue Code of 1986 (or treated as described in such section by reason of section 1361(d) of such Code), and Written determinations for this section These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. It appears that the IRS updates their listing every Friday.
In connection with the effectiveness of the certificate of dissolution, Tiger Logic will close its stock transfer books and discontinue recording transfers of its common stock, effective as of p.m. As a result, the common stock, and stock certificates evidencing the shares of common stock, will no longer be assignable or transferable on the Company's books, other than transfers by will, intestate succession or operation of law.
If any property distributed in the liquidation is subject to a liability or the shareholder assumes a liability of the liquidating corporation in connection with the distribution, for purposes of subsection (a) and section 337, the fair market value of such property shall be treated as not less than the amount of such liability. Stock owned (or treated as owned) by members of the same family (within the meaning of section 318(a)(1) of the Internal Revenue Code of 1986) shall be treated as owned by 1 person, and shall be treated as owned by such 1 person for any period during which it was owned (or treated as owned) by any such member.
For purposes of subparagraph (A), the term “disqualified property” means any property which is acquired by the liquidating corporation in a transaction to which section 351 applied, or as a contribution to capital, during the 5-year period ending on the date of the distribution. Stock owned (or treated as owned) by the estate of any decedent or by any trust referred to in subparagraph (B)(iii) with respect to such decedent shall be treated as owned by 1 person and shall be treated as owned by such 1 person for the period during which it was owned (or treated as owned) by such estate or any such trust or by the decedent.
The first Target store opened in Roseville, Minnesota in 1962 while the parent company was renamed the Dayton Corporation in 1967.
It became the Dayton-Hudson Corporation after merging with the J. Hudson Company in 1969 and held ownership of several department store chains including Dayton's, Hudson's, Marshall Field's, and Mervyn's.