When might a shareholder have to rely on the not essentially equivalent to a dividend test in

Question:

When might a shareholder have to rely on the not essentially equivalent to a dividend test in arguing her stock redemption should be treated as an exchange for tax purposes?

Dividend
A dividend is a distribution of a portion of company’s earnings, decided and managed by the company’s board of directors, and paid to the shareholders. Dividends are given on the shares. It is a token reward paid to the shareholders for their...