Jim owned 100% of the Rockford Files Corporation (RF). At the end of last year, RF had an NOL of $6,000,000. On January 1 of the current year, Jim sold all of his stock in RF to David for $8,000,000. For January of the current year, the long term tax exempt rate was 3%. At the time of the sale, RF only had one asset with a basis that was significantly different from its fair market value: a trailer in