Daisy Duck, Donald Duck, Minnie Mouse, and Mickey Mouse are trying to decide whether they should organize a corporation and transfer their shares of stock in several corporations to this new corporation. All their shares are listed on the New York Stock Exchange and are readily marketable. Daisy Duck would transfer shares in Bow Corporation; Donald Duck would transfer stock in Goofy Corporation; Minnie Mouse would transfer stock in Mouse Ears Corporation, and Mickey Mouse would transfer stock in several corporations. The stock would be held by the newly formed corporation for investment purposes. Daisy Duck asks you, her tax advisor, if she would have gain on the transfer of their substantially appreciated shares in Bow Corporation if she transfers the shares to a newly formed corporation. She also asks whether there will be tax consequences if she, Donald Duck, Minnie Mouse, and Mickey Mouse form a partnership, rather than a corporation, to which they would transfer their readily marketable stock. Your input will be critical as they make their decisions.

Required: Perform a research (all applicable IRC Codes, Regulations, Revenue Rulings, and Court Cases) and prepare a technical memo for the client Daisy Duck file describing the results of your research.

I need some help with the research, please.