Sec. 346. Definition and special rule
 
 (a) Complete liquidation
 For purposes of this subchapter, a distribution shall be treated
 as in complete liquidation of a corporation if the distribution is
 one of a series of distributions in redemption of all of the stock
 of the corporation pursuant to a plan.
 

Section 346(a)

Assumptions: X adopts a plan of liquidation. One month later X makes a first distribution in liquidation. The next year, X makes a second, final, distribution in liquidation.

Treatment: Both distributions are considered distributions in complete liquidation.

 
 
 (b) Transactions which might reach same result as partial
 liquidations
 The Secretary shall prescribe such regulations as may be
 necessary to ensure that the purposes of subsections (a) and (b) of
 section 222 of the Tax Equity and Fiscal Responsibility Act of 1982
 (which repeal the special tax treatment for partial liquidations)
 may not be circumvented through the use of section 355, 351, or any
 other provision of law or regulations (including the consolidated
 return regulations).