For purposes of a partial liquidation, the "not essentially equivalent to a dividend" test is applied at the corporate level.

Name: For purposes of a partial liquidation, the "not essentially equivalent to a dividend" test is applied at the corporate level.
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The "not essentially equivalent to a dividend" test is applied at the corporate level to determine whether a partial liquidation qualifies for favorable tax treatment.

For Purposes of a Partial Liquidation, the "Not Essentially Equivalent