Dress for Success is a 501 (c) (3) organization that provides clothes and job training to homeless individuals. Its annual operating

budget is $100 million. Steve Jobs, a philanthropist, would like to will his computer company, Apple Tools (a C. Corp) to Dress for

Success. Dress for Success has retained your services to provide an analysis of the tax consequences of each option.

(a) Sell the Apple Tools business and contribute the net proceeds to Dress for Success;

(b) Continue to operate the Apple Tools business as a division of Dress for Success;

(c) Continue to conduct the Apple Tools business as a wholly owned subsidiary of Dress for Success.