Contra Corporation Is Owned 50% by Terry and 50% by Sammy.Due

Contra Corporation is owned 50% by Terry and 50% by Sammy.Due to news articles damaging Contra's reputation,Terry and Sammy decide to liquidate Contra,which has been in existence for 4 years.They create Alpha and Beta Corporations to receive all of the manufacturing assets of Contra's two picture frame plants.Alpha receives the urban plant manufacturing assets and Beta receives the country manufacturing plant.Terry receives 60% Alpha stock and 40% of the Beta stock and Sammy receives 40% Alpha stock and 60% of the Beta stock.Terry and Sammy turn in their Contra stock and Contra then liquidates.Assuming all other requirements are met,how will this transaction be treated for tax purposes?

A) As a taxable transaction.
B) As a "Type A" deconsolidation.
C) As a "Type D" split-off reorganization.
D) As a "Type D" split-up reorganization.
E) None of the above.