S owns 60 percent of the 100 shares of LMN, Inc.stock outstanding.His dad owns 20 shares, and his friend J owns the remaining 20 shares.S also owns 50 percent of OPQ's 100 shares outstanding while J owns the other 50 percent.Assuming S sells 40 shares of LMN to OPQ for a gain of $5,000, he is assured of exchange treatment.
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