In 2022, T Corporation decides it will expand into the cold pressed juice market. The shareholders become aware of a struggling company that has $100,000 of NOLs, assets worth $20,000 and liabilities of $10,000 (assume all assets are business assets). T is owned by two equal shareholders (Dr. J and S. Dogg). Dr. J and S. Dogg are looking cut their losses and sell the business. On January 1, 2022, TJ Smoothie purchases all of Dr. J's stock and half of S. Dogg's stock for $12,000, resulting in TJ Smoothie owning 75% and S. Dogg retaining 25% of Tin