T Corp (T) has assets with fair market value of $210 and $150 adjusted basis. T also has an account payable of $10. T is wholly owned by Abby (basis $100; value $200). P Corp (P) is an unrelated entity and has a wholly owned subsidiary, Sub Inc. (S). Ps basis in S is $0. P Corp proposes to acquire Ts assets and liabilities under the following alternative transactions. T transfers all of its assets and liabilities to S. In exchange, S transferred $200 worth of Ps voting stock to T. The P stock transferred by S to T was contributed by P for the purpose of effectuating the acquisition of T