Section 338.—Certain Stock Purchases Treated as Asset Acquisitions

26 CFR 1.338-1: General principles: status of old target and new target.

What guidelines are provided for use by taxpayers and IRS personnel in making fair market value determinations for inventory items acquired when a taxpayer purchases the assets of a business for a lump sum or a corporation acquires the stock of another corporation and makes an election under section 338 of the Code. See Rev. Proc. 2003-51, page 121.