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Grant Corporation Transfers Highly Appreciated Stock to Subsidiary Corporation in Exchange

Question 99

Multiple Choice

Grant Corporation transfers highly appreciated stock to Subsidiary Corporation in exchange for all of its stock. The Subsidiary Corporation stock is distributed to its sole shareholder, Peter. Three weeks after the distribution of the Subsidiary stock, Subsidiary Corporation liquidates. Peter then sells the appreciated stock that he received in the liquidation. This series of transactions


A) does not meet the statutory definition of a divisive Type D reorganization.
B) fails the business purpose requirement.
C) results in a capital gain to Peter.
D) None of the above is correct.

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