Explain why a transaction might satisfy the letter of Sec. 368 for a reorganization yet fail to be treated as a reorganization.

A. A transaction can satisfy the letter of the reorganization provisions yet be treated by the IRS and the courts as a taxable transaction if it violates the business purpose doctrine, but meets the other judicial doctrines.

B. A transaction can satisfy the letter of the reorganization provisions yet be treated by the IRS and the courts as a taxable transaction if it violates one or more of the judicial doctrines.

C. A transaction might satisfy the requirements for Sec. 368 reorganizations but not be treated as a reorganization if the target corporation does not fully dissolve.

D. A transaction might satisfy the requirements for Sec. 368 reorganizationsbut not be treated as a reorganization if the IRS discovers the assets acquired are placed directly into an LLC owned by the acquiring corporation. This is in violation of the business purpose requirement.