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Rev. Rul. 67-269


Rev. Rul. 67-269; 1967-2 C.B. 298

DATED
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Citations: Rev. Rul. 67-269; 1967-2 C.B. 298

Obsoleted by Rev. Rul. 95-71

Rev. Rul. 67-269

An electing small business corporation, as defined by section 1371(b) of the Internal Revenue Code of 1954, issued options and warrants to acquire its stock. It also issued debentures convertible into its stock. These options, warrants and debentures have none of the attributes of immediate stock ownership, such as the right to vote in the capacity of a stockholder, or the right to receive dividends

Held , the mere issuance of these options, warrants, and convertible debentures does not terminate the corporation's election under section 1372(e) of the Code. Similarly, the mere issuance of such options, warrants or convertible debentures would not affect a corporation's eligibility to make an election under section 1372(a) of the Code.

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