Mickey Mouse, Minnie, Donald, and Daisy are seeking professional advice regarding whether they should organize a corporation and transfer their shares of stock in several corporations to this new corporation. The shares of each company are listed on the NYSE and are readily marketable. Mickey would transfer shares in Goofy Corporation, Minnie would transfer stock in Pete Corporation, Donald would transfer stock in Pluto Corporation, and Daisy would transfer stock in several corporations. The newly formed corporation for investment purposes would hold the stock. Mickey asks you, his tax adviser, whether he would have gain on the transfer of his substantially appreciated shares in Goofy Corporation if he transferred the shares to a newly formed corporation. Your input will be critical as they make their decision. Prepare a letter to your client, Mickey Mouse, and a memo for the firms.