Prepare a memorandum for tax manager

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Reference no: EM13504697

Bob and Carl transfer property to Stone Corporation for 90% and 10% of Stone Stock, respectively. Pursuant to a biding agreement concluded before the transfer, Bob sells half of his stock to CArl. Prepare a memorandum for your Tax MAnager explaining why the exchange does or does not mee the Sec 351 control requirements. Your Manager has sugested that, at a minimum you consult the following authorities:

IRC Sec 351

IRC Sec 1.351-1

Reference no: EM13504697

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