Facts

Gray Corporation has offices in several states. As part of its employee relocation package, Gray Corporation pays for moving expenses and assists in the sale of the transferred employees home. If the employee cannot sell his or her home before the move, Gray Corporation purchases the home for its appraised value.

Issue

What is the character of Gray Corporations gain or loss on the subsequent sale of these homes?

The only thing I need help with is finding the RELEVANT INTERNAL REVENUE CODE that would outline the treatment of Gray Corporation's gain or loss. Please describe the appropriate IRS Section to look into to determine its treatment. I have searched Thomas Reuter's Checkpoint data base for hours and cannot find an appropriate IRC section. That is all I need. Thank you so much.