26 C.F.R. § 1.317-1 Property defined.
Title 26 - Internal Revenue
The term property, for purposes of part 1, subchapter C, chapter 1 of the Code, means any property (including money, securities, and indebtedness to the corporation) other than stock, or rights to acquire stock, in the corporation making the distribution.
Title 26: Internal Revenue
PART 1—INCOME TAXES
definitions; constructive ownership of stock
§ 1.317-1 Property defined.