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Dirty Corporation Has Owned Two Chemical Manufacturing Facilities for the Last

Question 71

Multiple Choice

Dirty Corporation has owned two chemical manufacturing facilities for the last 20 years.One facility is located in Oklahoma while the other is in Oregon.There have been some environmental investigations at the Oregon facility.Therefore,Dirty creates a new corporation,called Clean,and places the assets of the Oregon plant into Clean in exchange for all of Clean's stock.Dirty distributes this stock proportionately to its shareholders in exchange for 40% of their Dirty stock.How will this transaction be treated for tax purposes?


A) As a split-up "Type D" reorganization.
B) As a split-off "Type D" reorganization.
C) As a spin-off "Type D" reorganization.
D) This transaction does not qualify as a reorganization,because Dirty does not have two active lines of business.
E) None of the above.

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