26 C.F.R. § 1.346-3 Effect of certain sales.
Title 26 - Internal Revenue
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.
Title 26: Internal Revenue
PART 1—INCOME TAXES
definition
§ 1.346-3 Effect of certain sales.