A shareholder's holding period for stock received under § 351 can include the holding period of the property transferred to the corporation.

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Under § 351 of the Internal Revenue Code, if a shareholder transfers property to a corporation in exchange for stock in such corporation and immediately after the exchange is in control of the corporation, the shareholder's holding period for the stock received includes the holding period of the property transferred, provided the property transferred was a capital asset or a Section 1231 asset.

A Shareholder's Holding Period for Stock Received Under § 351