PLEASE READ THIS: I HAVE ALREADY TALKED ABOUT A MAJORITY OF THE NECESSARY INFORMATION SO PLEASE DO NOT RESTATE WHAT I ALREADY TALKED ABOUT. THE ONLY THING I NEED HELP WITH IS THE FOLLOWING:

1. How control is defined and how we know whether both of these transactions meet that definition.

Already talked about section 351 and 80% rule. So please do not just use the same answer as other chegg questions.

Shirley and Roseann form Rosa Corporation with each contributing assets and cash in exchange for all of the corporation's stock. Shirley and Roseann each own 50% of the stock immediately after the exchange. Shortly thereafter, Shirley sells all her stock to Don per a written agreement executed before the formation of Rosa Corporation. Prepare a memorandum discussing the effect of this prearranged agreement