Maureen owns all of the stock in Green Corporation. Green owns 10,000 shares of Micro Corporation, whose value has increased by 1000% since they were purchased eight years ago. Maureen would like to have the shares distributed to her, but she wants to avoid the tax bill that would result if they were distributed as a dividend from Green Corporation. Her son, who is taking classes for his MBA, has suggested that she create Brown Corporation with herself as the sole shareholder, and have Green transfer the stock to Brown. Following this, Brown could be liquidated, and she would receive the Micro stock in return for her shares of Brown. This would achieve capital gains treatment for Maureen. Maureen is your client. What advice would you give her about this proposed transaction, and what authorities would you cite