Chris and Kris run a business together as husband and wife. However, Chris loves cash accounting while Kris loves accrual accounting. This leads to their divorce during 2017. Kris and Chris didn't want the general public to know about their divorce because they feared it would hurt their business reputation. As part of the divorce settlement they each take fifty percent ownership of the shares but do not split the shares. The shares are still in both of their names to maintain the illusion of joint ownership of their business. In 2020 Kris met Cristian Christopherson who also loves accrual accounting. They get married and want half of Kris's shares to be retitled to her new married name Christopherson. The divorce court concedes to Kris's request and grants her half of the shares. Will the transfer of shares be subject to income tax? Subject to gift tax? Write a memo addressing this tax issue. The memo portion of your response should be no longer than two pages. However, please attach your source material at the end of your memo.