§678. Person other than grantor treated as substantial owner — Inbound Citations

Citations to §678(a)

• 26 U.S.C. § 1361(d)(1)(B)

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  (B) for purposes of section 678(a), the beneficiary of such trust shall be treated as the owner of that portion of the trust which consists of stock in an S corporation with respect to which the election under paragraph (2) is made, and