Big Corp acquired a 25% interest in Small Corp 2 years ago by exchanging $375,000 of its preferred stock with A, one of Smalls shareholders. Big tried to acquire the assets of Small but was denied by the Small Board of Directors. In the current year, Big acquires $712,500 of Smalls voting common and $200,000 of preferred shares. Big now owns 95% of the Small common and 100% of preferred. What are the tax issues with respect to this transaction as it