)Bob and Carl transfer property to stone Corporation for 90 percent and 10 Percent of stone stock, respectively.pursuant to binding 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 meet the sec.351 control requirement.. your manager has suggested that, at a minimum, you consult the following authorities: IRS Sec.351 IRS.Sec.1.351-1