G Inc.is a successful operator of golf courses, golf tournaments, and related retail shops.G Inc. has been in existence for many years and has substantial earnings and profits.G Inc is owned equally by four individuals: Arnie, Arnie's son Jack, Arnie's grandson Phil, and Tiger who became a stockholder more recently.Each individual owns 25% of the outstanding stock, and each works full time in the business. The tax basis for 6 shares is $1,000,000.

Arnie has decided to retire and concentrate on a different business.He wants G Inc to buy out his entire interest.He has a capital loss carryover, so he wants the redemption to qualify as a capital gain.

What are thetax consequences of the situation above? (any relative IRC Sections?)