California Revenue and Taxation Code § 17855

Revenue and Taxation Code
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The term “unrealized receivables,” as defined by Section 751(c) of the Internal Revenue Code, shall not include any of the following: (a) Stock in certain foreign corporations, as described in Section 1248 of the Internal Revenue Code. (b) Oil, gas, or geothermal property, described in Section 1254 of the Internal Revenue Code.

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