In a partial liquidation a company redeems all or part of its outstanding stock then distributes the proceeds to its shareholders.
were distributed among its three shareholders in such manner as to make the totality of its distributions pro rata.
, except that 100% of Whiteacre was distributed to C and the remaining assets of X Co.
constituting more than 50% of the value of X Co.'s outstanding stock ( 267(b)(2)).
While Whiteacre was not distributed pro rata among X Co.'s shareholders, it was not distributed to a related person (within the meaning of 267).
This mainly occurs during voluntary liquidations of solvent corporations.