Sec 351 of income tax act, Taxation

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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 me the Sec 351 control requirements. Your Manager has suggested that, at a minimum you consult the following authorities:

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