1. Lemon Corporation has been engaged in the manufacture and sale of personal computer hardware equipment for ten years at two plants, one in Boston, Massachusetts and the other in San Jose, California. During this same period, Lemon also has operated at each location a separate research and development division, each of which had significant assets and goodwill. Lemon's common stock, the only class outstanding, is owned equally by Ms. Micro and Mr. Chips. In each of the following alternative transactions, consider whether the active trade or business requirement has been satisfied: (a) As a result of a shareholder dispute, Ms. Micro wishes to say goodbye to Mr. Chips. To enable the shareholders to part company but continue in the computer business, Lemon contributes the assets and research division of the Boston facility to a new corporation, Peach, Inc., and distributes all the Peach, Inc. stock to Mr. Chips in redemption of his Lemon stock. Ms. Micro remains as the sole shareholder of Lemon. (b) Same as (a), above, except that the Boston facility was opened only three years ago. (c) Same as (b), above, except that three years ago Lemon acquired all the stock of Peach, Inc., which operated the Boston facility, for cash