For the Last 10 Years,Contra Corporation Has Owned Two Plants

For the last 10 years,Contra Corporation has owned two plants for manufacturing picture frames.One plants is located in an urban area while the other is in the country.There have been some protests at the urban plant regarding air pollution.Therefore,Contra decides to create a new corporation,called Alpha,and place the assets of the urban plant into Alpha in exchange for all of Alpha's stock.Contra distributes this stock proportionately to its shareholders in exchange for 40% of their Contra stock.

A) This transaction qualifies as an acquisitive "Type D" reorganization.
B) This transaction qualifies as a spin-off "Type D" reorganization.
C) This transaction qualifies as a split-up "Type D" reorganization.
D) This transaction does not qualify as a reorganization, because Contra does not liquidate after the transaction.
E) None of the above statements is correct.