Griswold Corporation has one class of common stock outstanding, which is owned equally by Clark and Eddie. Each shareholder owns 1000 shares. Clark's basis is $900,000, Eddie's basis is $12,000,000. The fair market value of each share of Griswold is $10,000. The aggregate value of the shares is $20,000,000. Griswold directly operates two distinct businesses, "Wings," an air charter business with three airplanes, and "Wally World," an amusement park. Griswold also owns all of the stock of Caddy Shack Golf Club Manufacturing, Inc., which it has held for seven years. What are the tax consequences of the following alternative transactions?