Eta counters and suggests a "Type C" reorganization as a method of acquiring all of MuCo by exchanging its voting stock for all assets (now worth $1.5 million) and all liabilities ($650,000) of MuCo. The other division of MuCo, Cat Publications, is small, with assets worth $200,000 and liabilities of $150,000. Lily agrees to the reorganization if MuCo receives the net value of the Cat Publication division ($50,000) in cash, as Lily would like money as well as stock.

Lily requests your advice on whether the transaction can be structured as a "Type C" reorganization as it is currently described. If it cannot meet the "Type C" requirements, suggest an alternative plan that will allow the transaction to qualify as a "Type C" reorganization. MuCo's address is 3443 E. Riverbank Road, Walla Walla, WA 99362. Include a memo and a letter to Ms. White. Please answer your analysis in a letter to Ms. White.