The holding company ABC co. is owned 50% by Rick and 50% by Tony. The company invests in real estate bonds and stocks, land and buildings from different enterprises, including XYZ, Inc.; Apples, Inc.; and Betty DeRose, LLC. In order to avoid personal holding company tax, Rick and Tony plan to liquidate ABC co. within the next quarter. Please consider the following questions with respect to this case:

In which case would the open doctrine apply to ABC co.?

Can ABC co. change its market composition/activities to decrease personal holding company tax?