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Clear Channel and CBS Radio were both far too large to accomplish the reverse Morris Trust structure, but they could have bid for the ABC

Clear Channel and CBS Radio were both far too large to accomplish the reverse Morris
Trust structure, but they could have bid for the ABC Radio assets with cash. Suppose
that Disney had sold the ABC stock to Clear Channel or CBS Radio in a deal for cash
only (no stock consideration), and that all parties agreed to make a 338(h)(10)election.
How much would Clear Channel or CBS Radio have had to offer for ABC Radio in
order for Disney to receive the same amount of compensation after taxes as Disney and its shareholders received under the tax-free transaction with Citadel (as
calculated in question 1)?(Assume Disney faced a 35% marginal tax rate.) Do you think
either Clear Channel or CBS Radio would have been willing to make such an offer?

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