5. [8\%] In doing a tax-free reorganization pursuant to IRC 368, taxpayers must (as you know) satisfy the statutory requirements of IRC \& 368 (for definitional purposes) and various other IRC sections to determine basis of assets, gain recognition, basis of stock, etc. Additionally, however, there are three judicially developed requirements (which are now also reflected in the tax statutes and/or regulations) applicable to tax-free (or tax deferred) reorganizations that taxpayers must meet to ensure the tax-free (or tax deferred) treatment the taxpayers report will be accepted by the IRS and the courts. What are these three requirements, and, briefly, what is the tax objective (or tax policy) for each requirement