### Prepare a memorandum for your tax manager

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##### Reference no: EM13320510

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

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