Purple Corporation is acquiring Gray Corporation in a transaction that qualities as a $368 reorganization by exchanging S650,000 of stock and two parcels (Parcel 1 FMV s350,000- Basis $50,000); (Parcel 2 FMV S250,000- Basis $100,000)] for all of Gray's assets (Stock- $450,000 and land (FMV of $500,000 and basis of $350,000) and liabilities of S175,000. Gray also has 200,000 of Earnings & Profits. Gray sells parcel #1 for its FMV and uses proceeds to compensate employees who are losing their jobs. Gray then liquidates, transferring the stock received and other land (parcel 2) to its shareholders. What are the tax consequences of the reorganization to all parties (the acquiring corporation, the target corporation and the shareholders of Gray Corporation)?